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Federal Reserve Racial and Economic Equity Act
Legislative Progress
Momentum (last 30 days)
0
score
0 actions · 0 new cosponsors · 0 votes
Speed vs cohort
95pct
433d open
vs 9,698 other HR bills in the 117th — cohort avg 63d
Financial Services Racial Equity, Inclusion, and Economic Justice Act This bill address access to financial services, diversity in various financial institutions and establishments, and other related issues. Access to credit, mortgages, and banking services are expanded, including by prohibiting discrimination with respect to credit transactions on the basis of an applicant's sexual orientation, gender identity, or location based on zip code or census tract; establishing language translation requirements for residential mortgage applications; and providing funding set-asides for minority lending institutions. The bill expands the support of, and access to, minority depository institutions and community development financial institutions and establishes an impact bank designation for small institutions that predominately lend to low-income borrowers. Further, the Federal Reserve Board must carry out its duties in a manner that supports the elimination of racial and ethnic disparities in employment, income, wealth, and access to affordable credit. Additionally, the bill requires financial institutions to report information relating to diversity policies and lending practices. Retail businesses must accept cash as a form of payment for sales in amounts less than $2,000 and are prohibited from charging cash-paying customers a higher price. Finally, the bill commissions various reports and studies, including a report from the Government Accountability Office on public housing for the homeless.
Yes
1357
No
1156
Present
0
Not Voting
55
Party Breakdown
These links require the bill number to appear in the filing's source-reported specific issue text. Client expenses and lobbying-firm income are separate disclosure fields.
Filing registrants (21)
Received in the Senate and Read twice and referred to the Committee on Banking, Housing, and Urban Affairs.
Motion to reconsider laid on the table Agreed to without objection.
On passage Passed by the Yeas and Nays: 215 - 207 (Roll no. 275).
HousePassed/agreed to in House: On passage Passed by the Yeas and Nays: 215 - 207 (Roll no. 275).
HouseOn motion to recommit Failed by the Yeas and Nays: 202 - 219 (Roll no. 274).
HouseThe previous question on the motion to recommit was ordered pursuant to clause 2(b) of rule XIX.
Mr. Hill moved to recommit to the Committee on Financial Services. (text: CR H5589)
The previous question was ordered pursuant to the rule.
POSTPONED PROCEEDINGS - At the conclusion of debate on the Payne amendment, the Chair put the question on adoption of the amendment and by voice vote, announced that the ayes had prevailed. Mr. McHenry demanded the yeas and nays and the Chair postponed further proceedings until a time to be announced.
Bills with similar content found using semantic analysis.
Sources: Congress.gov · House Clerk roll-call votes
| house |
| On Passage |
Passed |
| June 15, 2022 |
| #270 | house | On Agreeing to the Amendment | Agreed to | June 15, 2022 |
| #271 | house | On Agreeing to the Amendment | Failed | June 15, 2022 |
| #274 | house | On Motion to Recommit | Failed | June 15, 2022 |
| #272 | house | On Agreeing to the Amendment | Agreed to | June 15, 2022 |
| #273 | house | On Agreeing to the Amendment | Agreed to | June 15, 2022 |
2022 · fourth_quarter · Financial Institutions/Investments/Securities
Oppose inclusion of H.R. 7 Paycheck Fairness Act in H.R.2617 Consolidated Appropriations Act, 2023 Oppose inclusion of H.R.2543 - Federal Reserve Racial and Economic Equity Act in H.R.2617 Consolidated Appropriations Act, 2023
Client expense: $9,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2022 · fourth_quarter · Banking
S.2417, Credit Access and Inclusion; provisions pertaining to consumer credit, alternative data and financial inclusion. H.R.4120, Comprehensive Credit Reform Act; provisions pertaining to consumer credit. Issues pertaining to consumer finance, consumer credit, buy now pay later lending, and treatment of medical debt in credit reporting. S.1838, Building Credit Access for Veterans Act, issues pertaining to alternative data and credit reporting. H.R.7526, Servicemembers' Credit Monitoring Enhancement Act, issues pertaining to credit monitoring. H.R.6814 Small Business Fair Debt Collection Protection Act, issues pertaining to fair debt collection. National Credit Reporting Agency Act, issues pertaining to credit reporting. H.R.2543, Federal Reserve Racial and Economic Equity Act, issues pertaining to alternative data in mortgage underwriting, negative information on credit reports, medical debt, and credit checks for employment. H.R.8985 Credit Access and Inclusion Act, issues pertaining to credit reporting . McHenry GLBA Modernization Proposal.
Client expense: $430,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2022 · fourth_quarter · Banking
Protect the credit union tax exemption; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Support regulatory relief for credit unions; Provide guidance or rulemakings rather than rule through enforcement; Support increase in funding for CDFI Fund, MDIs, and the CDRLF; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; Support extending GLBA like data security measures to retailers; Support recognizing GLBA compliance in any privacy legislation; Oppose SBA direct lending authority; Support improvements to ease the process for forgiveness of PPP loans to small businesses; Oppose limits on fee income for credit unions including courtesy pay; Support CFPB study of overdraft programs to determine the value to consumers; Support limiting burdens of HMDA rule on credit unions; CFPB should remove unnecessary and unused data points related to HMDA reporting; Support permanently increasing reporting thresholds for open- and closed-end loans; Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; CFPB should engage in interagency coordination on Section 1033 consumer access to financial records rulemaking; Oppose CFPBs characterization of regulated and disclosed financial services fees as junk fees; CFPB should explore streamlining required fee disclosures; CFPB should clarify UDAAP authority; CFPB should respect GLBAs data security regulatory structure; CFPB should limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); Improve examination coordination between CFPB and NCUA; Support permanent adoption of CFPBs expired temporary relief of E-SIGN regulation; Support CFPB exercise of larger participant authority to oversee fintech companies; Support fair distribution of Regulation E error resolution responsibilities; Support clear regulatory framework for digital assets to encourage responsible innovation and permit credit union participation; Support CDFI Fund transparency on certification changes; Support streamlining and modernization of CDFI Fund certification process; Support Congressional oversight of SBAs Affiliation and Small Business Lending Company proposed rules; Support tax deduction for mortgage insurance premiums; Support modification or removal of the credit union member business lending cap; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; Support alternative credit scoring models; Oppose development of a CBDC; Support prevention of an NFIP lapse; Support improving veterans access to capital by exempting credit unions business loans to veterans from the credit union member business lending cap; Support expanding the definition of Community Financial Institutions (CFIs) in the Federal Home Loan Bank Act (FHLB Act) to include credit unions and Treasury-certified non-depository community development financial institutions; Oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; Support parity for credit unions related to stablecoin regulation; Treasury should address the demand for coins to help consumers who rely on cash transactions; Support addressing appraisal bias and modernize the appraisal process for consistency; Support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support easing requirements for de novo credit unions; Support providing flexibility for credit unions to issue subordinated debt; Support H.R. 5189, the Member Business Loan Expansion Act; Support the Federal Home Loan Banks' Mission Implementation Act (H.R. 3323, S.1684); Support H.R. 4773, the Consumer Financial Protection Commission Act; Oppose legislation granting NCUA third-party vendor examination authority (H.R. 7022, S. 4698); Oppose Credit Card Competition Act (H.R. 8874, S. 4674); Support SAFE Banking Act (H.R. 1996, S. 910); Support Central Liquidity Facility Enhancement Act (H.R. 3958, S. 5183); Support Credit Union Board Modernization Act (H.R. 6889, S. 4325); Support Expanding Financial Access for Underserved Communities Act (H.R. 7003, S. 4879); Support CDFI Bond Guarantee Program Improvement Act (H.R. 7733, S. 3441); Support Title III, Subtitle C of H.R. 2543 - Promoting and Advancing Communities of Color Through Inclusive Lending; Support S. 3590, the Middle Class Mortgage Insurance Premium Act; Oppose inclusion of the Credit Card Competition Act (H.R. 8874, S. 4674) or NCUA third-party vendor examination authority (H.R. 7022, S. 4698) in the FY 2023 NDAA; Support H.R. 5912, the Close the ILC Loophole Act; Support S. 762, the Expanding Access to Lending Options Act; Oppose Senate NDAA amendments 6201 and 6174 on credit card interchange; Support S. 4165, the CDFI Crisis Fund Act; Oppose H.R. 4277, the Overdraft Protection Act; Oppose FDCPA changes that improperly burden creditors in H.R. 6814, the Small Business Fair Debt Collection Protection Act; Oppose inclusion of bank lease provision in FY 2023 NDAA; Oppose H.R. 8152, the American Data Privacy and Protection Act; Support H.R. 5911, the Fair Hiring in Banking Act; Support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; Oppose H.R. 8485, the Expanding Access to Credit through Consumer-Permissioned Data Act; Support the Small LENDER Act (H.R. 6732, S. 4004); Support H.R. 7628, the Improve the SBA Act; Support the SECURE Notarization Act (H.R. 3962, S. 1625); Support the TAILOR Act (H.R. 766, S. 3745); Support the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act (H.R. 7412, S.4522); Support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; Oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; Support S. 5189, the Close the Shadow Banking Loophole Act; Support for Advancing Technologies to Support Inclusion Act discussion draft; Support for Creation of Diverse and Mission-Driven Community Financial Institutions Act discussion draft; Comments to SBA on RIN 3245-AH87 expressing concern about interaction between Affiliation and Small Business Lending Company proposed rules; Request for extension of temporary NCUA relief on loan participation and eligible obligation regulations due to the COVID-19 pandemic; Request for clarification of CFPB authority and intention for auto loan data collection; Comments to Treasury Dept on Docket No. 2022-21524 requesting streamlined applications for federal community investment programs; Comments to CDFI Fund on Docket No. 2022-22767 requesting modification of proposed pre-approved Target Market assessment methodologies; Comments to EPA on Docket ID No. EPA-HQ-OA-2022-0859 opposing establishment of single national green bank and supporting credit union inclusion as indirect recipients of Greenhouse Gas Reduction Fund disbursements; Comments to NCUA on RIN: 3133-AF43 supporting the elimination of the maximum maturity requirement for subordinated debt; Comments to CDFI Fund on Docket No. 2022-24082 opposing changes to CDFI certification requirements; Comments to NCUA on Docket No. NCUA-2022-0132 opposing overly complex member expulsion process; Support delay of GSEs credit fee caps effective date; Comments to CFPB on Docket No. CFPB-2022-0059 supporting additional flexibility in the Qualified Mortgage rule; Comments to FTC on R111004 opposing data privacy rulemaking absent comprehensive federal legislation; Support elimination of in-person quorum requirement for credit union annual meetings; Comments to CISA on Docket ID: CISA-2022-0010 supporting simplification of cyber incident reporting requirements; Support inclusion of 501(c)(19) veterans organizations as qualified charit[ies] in NCUA regulations; Comments to Treasury Department on Document No. 2022-20279 supporting application of Bank Secrecy Act and anti-money laundering regulations to digital assets and supporting interagency coordination to ensure credit union inclusion in digital asset regulations; Comments to FHFA on Federal Home Loan Bank System review supporting capital requirements for System members and supporting alignment of tangible capital definitions among regulators; Comments to FHFA on Fintech in Housing Finance supporting interagency coordination and caution in integration of non-depository fintech lenders; Comments to NCUA on RIN 3064-ZA33 supporting flexibility in updated commercial real estate loan accommodations policy statement; Oppose increases to NCUAs 2023-2024 budget and support increased budget transparency; Oppose expansion of Regulation E liability;
2022 · fourth_quarter · Financial Institutions/Investments/Securities
Protect the credit union tax exemption; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Support regulatory relief for credit unions; Provide guidance or rulemakings rather than rule through enforcement; Support increase in funding for CDFI Fund, MDIs, and the CDRLF; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; Support extending GLBA like data security measures to retailers; Support recognizing GLBA compliance in any privacy legislation; Oppose SBA direct lending authority; Support improvements to ease the process for forgiveness of PPP loans to small businesses; Oppose limits on fee income for credit unions including courtesy pay; Support CFPB study of overdraft programs to determine the value to consumers; Support limiting burdens of HMDA rule on credit unions; CFPB should remove unnecessary and unused data points related to HMDA reporting; Support permanently increasing reporting thresholds for open- and closed-end loans; Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; CFPB should engage in interagency coordination on Section 1033 consumer access to financial records rulemaking; Oppose CFPBs characterization of regulated and disclosed financial services fees as junk fees; CFPB should explore streamlining required fee disclosures; CFPB should clarify UDAAP authority; CFPB should respect GLBAs data security regulatory structure; CFPB should limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); Improve examination coordination between CFPB and NCUA; Support permanent adoption of CFPBs expired temporary relief of E-SIGN regulation; Support CFPB exercise of larger participant authority to oversee fintech companies; Support fair distribution of Regulation E error resolution responsibilities; Support clear regulatory framework for digital assets to encourage responsible innovation and permit credit union participation; Support CDFI Fund transparency on certification changes; Support streamlining and modernization of CDFI Fund certification process; Support Congressional oversight of SBAs Affiliation and Small Business Lending Company proposed rules; Support tax deduction for mortgage insurance premiums; Support modification or removal of the credit union member business lending cap; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; Support alternative credit scoring models; Oppose development of a CBDC; Support prevention of an NFIP lapse; Support improving veterans access to capital by exempting credit unions business loans to veterans from the credit union member business lending cap; Support expanding the definition of Community Financial Institutions (CFIs) in the Federal Home Loan Bank Act (FHLB Act) to include credit unions and Treasury-certified non-depository community development financial institutions; Oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; Support parity for credit unions related to stablecoin regulation; Treasury should address the demand for coins to help consumers who rely on cash transactions; Support addressing appraisal bias and modernize the appraisal process for consistency; Support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support easing requirements for de novo credit unions; Support providing flexibility for credit unions to issue subordinated debt; Support H.R. 5189, the Member Business Loan Expansion Act; Support the Federal Home Loan Banks' Mission Implementation Act (H.R. 3323, S.1684); Support H.R. 4773, the Consumer Financial Protection Commission Act; Oppose legislation granting NCUA third-party vendor examination authority (H.R. 7022, S. 4698); Oppose Credit Card Competition Act (H.R. 8874, S. 4674); Support SAFE Banking Act (H.R. 1996, S. 910); Support Central Liquidity Facility Enhancement Act (H.R. 3958, S. 5183); Support Credit Union Board Modernization Act (H.R. 6889, S. 4325); Support Expanding Financial Access for Underserved Communities Act (H.R. 7003, S. 4879); Support CDFI Bond Guarantee Program Improvement Act (H.R. 7733, S. 3441); Support Title III, Subtitle C of H.R. 2543 - Promoting and Advancing Communities of Color Through Inclusive Lending; Support S. 3590, the Middle Class Mortgage Insurance Premium Act; Oppose inclusion of the Credit Card Competition Act (H.R. 8874, S. 4674) or NCUA third-party vendor examination authority (H.R. 7022, S. 4698) in the FY 2023 NDAA; Support H.R. 5912, the Close the ILC Loophole Act; Support S. 762, the Expanding Access to Lending Options Act; Oppose Senate NDAA amendments 6201 and 6174 on credit card interchange; Support S. 4165, the CDFI Crisis Fund Act; Oppose H.R. 4277, the Overdraft Protection Act; Oppose FDCPA changes that improperly burden creditors in H.R. 6814, the Small Business Fair Debt Collection Protection Act; Oppose inclusion of bank lease provision in FY 2023 NDAA; Oppose H.R. 8152, the American Data Privacy and Protection Act; Support H.R. 5911, the Fair Hiring in Banking Act; Support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; Oppose H.R. 8485, the Expanding Access to Credit through Consumer-Permissioned Data Act; Support the Small LENDER Act (H.R. 6732, S. 4004); Support H.R. 7628, the Improve the SBA Act; Support the SECURE Notarization Act (H.R. 3962, S. 1625); Support the TAILOR Act (H.R. 766, S. 3745); Support the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act (H.R. 7412, S.4522); Support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; Oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; Support S. 5189, the Close the Shadow Banking Loophole Act; Support for Advancing Technologies to Support Inclusion Act discussion draft; Support for Creation of Diverse and Mission-Driven Community Financial Institutions Act discussion draft; Comments to SBA on RIN 3245-AH87 expressing concern about interaction between Affiliation and Small Business Lending Company proposed rules; Request for extension of temporary NCUA relief on loan participation and eligible obligation regulations due to the COVID-19 pandemic; Request for clarification of CFPB authority and intention for auto loan data collection; Comments to Treasury Dept on Docket No. 2022-21524 requesting streamlined applications for federal community investment programs; Comments to CDFI Fund on Docket No. 2022-22767 requesting modification of proposed pre-approved Target Market assessment methodologies; Comments to EPA on Docket ID No. EPA-HQ-OA-2022-0859 opposing establishment of single national green bank and supporting credit union inclusion as indirect recipients of Greenhouse Gas Reduction Fund disbursements; Comments to NCUA on RIN: 3133-AF43 supporting the elimination of the maximum maturity requirement for subordinated debt; Comments to CDFI Fund on Docket No. 2022-24082 opposing changes to CDFI certification requirements; Comments to NCUA on Docket No. NCUA-2022-0132 opposing overly complex member expulsion process; Support delay of GSEs credit fee caps effective date; Comments to CFPB on Docket No. CFPB-2022-0059 supporting additional flexibility in the Qualified Mortgage rule; Comments to FTC on R111004 opposing data privacy rulemaking absent comprehensive federal legislation; Support elimination of in-person quorum requirement for credit union annual meetings; Comments to CISA on Docket ID: CISA-2022-0010 supporting simplification of cyber incident reporting requirements; Support inclusion of 501(c)(19) veterans organizations as qualified charit[ies] in NCUA regulations; Comments to Treasury Department on Document No. 2022-20279 supporting application of Bank Secrecy Act and anti-money laundering regulations to digital assets and supporting interagency coordination to ensure credit union inclusion in digital asset regulations; Comments to FHFA on Federal Home Loan Bank System review supporting capital requirements for System members and supporting alignment of tangible capital definitions among regulators; Comments to FHFA on Fintech in Housing Finance supporting interagency coordination and caution in integration of non-depository fintech lenders; Comments to NCUA on RIN 3064-ZA33 supporting flexibility in updated commercial real estate loan accommodations policy statement; Oppose increases to NCUAs 2023-2024 budget and support increased budget transparency; Oppose expansion of Regulation E liability;
2022 · fourth_quarter · Economics/Economic Development
Extending and modifying the CDFI Bond Guarantee Program. Worked to advance the CDFI Bond Guarantee Program Improvement Act of 2022 (S.3441 and H.R.7733) that passed the House as part of the Financial Services Racial Equity, Inclusion, and Economic Justice Act (H.R.2543) on June 15, 2022; as well as H.R. 7900 to authorize appropriations for FY 2023 for Military activities of the Dept. of Defense and for Military construction.
Client expense: Not reported · Firm income: $10,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
DEBATE - Pursuant to the provisions of H. Res. 1170, the House proceeded with 10 minutes of debate on the Payne amendment No. 19.
POSTPONED PROCEEDINGS - At the conclusion of debate on the Vicente Gonzalez amendment, the Chair put the question on adoption of the amendment and by voice vote, announced that the ayes had prevailed. Mr. Posey demanded the yeas and nays and the Chair postponed further proceedings until a time to be announced.
DEBATE - Pursuant to the provisions of H. Res. 1170, the House proceeded with 10 minutes of debate on the Vicente Gonzalez amendment No. 10.
POSTPONED PROCEEDINGS - At the conclusion of debate on the Green (TX) amendment en bloc No. 2, the Chair put the question on adoption of the amendment and by voice vote, announced that the ayes had prevailed. Mr. Al Green (TX) demanded the yeas and nays and the Chair postponed further proceedings until a time to be announced.
DEBATE - Pursuant to the provisions of H. Res. 1170, the House proceeded with 20 minutes of debate on the Al Green (TX) amendment en bloc No. 2.
POSTPONED PROCEEDINGS - At the conclusion of debate on the Green (TX) amendment en bloc No. 1, the Chair put the question on adoption of the amendment and by voice vote, announced that the ayes had prevailed. Mr. McHenry demanded the yeas and nays and the Chair postponed further proceedings until a time to be announced.
DEBATE - Pursuant to the provisions of H. Res. 1170, the House proceeded with 20 minutes of debate on the Al Green (TX) amendment en bloc No. 1.
DEBATE - The House proceeded with one hour of debate on H.R. 2543.
Rule provides for consideration of H.R. 2543, H.R. 2773 and H.R. 7606. Resolution provides for one hour of general debate on each bill and one motion to recommit. Rule also amends House Resolution 188 by striking "June 17, 2022" and inserting "June 22, 2022".
Considered under the provisions of rule H. Res. 1170. (consideration: CR H5556-5591; text: CR H5556-5567)
Rules Committee Resolution H. Res. 1170 Reported to House. Rule provides for consideration of H.R. 2543, H.R. 2773 and H.R. 7606. Resolution provides for one hour of general debate on each bill and one motion to recommit. Rule also amends House Resolution 188 by striking "June 17, 2022" and inserting "June 22, 2022".
Placed on the Union Calendar, Calendar No. 162.
Reported (Amended) by the Committee on Financial Services. H. Rept. 117-228.
Congress.gov source codes: 5000, H12200
Ordered to be Reported (Amended) by the Yeas and Nays: 30 - 23.
Committee Consideration and Mark-up Session Held.
Committee Consideration and Mark-up Session Held.
Referred to the House Committee on Financial Services.
Introduced in House
Congress.gov source codes: 1000, Intro-H
| House |
| Markup by |
| April 20, 2021 |
| Financial Services Committee | House | Referred to | April 14, 2021 |
| April 14, 2021 |
| Democratic |
| OH |
| Nikema Williams | Democratic | GA |
| S 374 |
117th |
| Related bill |
| S 3441 | 117th | Related bill |
| S 1327 | 117th | Related bill |
| HRES 1170 | 117th | Related bill |
| HR 9706 | 117th | Related bill |
| HR 9643 | 117th | Related bill |
| HR 9607 | 117th | Related bill |
| HR 8485 | 117th | Related bill |
| HR 7978 | 117th | Related bill |
| HR 7953 | 117th | Related bill |
| HR 7733 | 117th | Related bill |
| HR 7003 | 117th | Related bill |
| HR 6745 | 117th | Related bill |
| HR 4590 | 117th | Related bill |
| HR 3009 | 117th | Related bill |
| HR 166 | 117th | Related bill |
| HR 1443 | 117th | Related bill |
| HR 1277 | 117th | Related bill |
Client expense: $910,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA), White House Office
Client expense: $910,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA), White House Office
2022 · fourth_quarter · Housing
H.R. 2483/S. 3237, Build More Housing Near Transit Act of 2021; H.R. 2126/S. 902, Housing Supply and Affordability Act; H.R. 3198/S. 1614, Yes in my Backyard Act; H.R. 6307, Tiny Homes for Homeless Veterans; Housing, Opportunity, Mobility, and Equity (HOME) Act; Build Back Better; S. 768, Better Planning and Land-Use for Accessible Neighborhoods Act; H.R. 1615, Maximizing Our Redevelopment and Efficiency for Transit Oriented Development (More TOD) Act of 2021; Task Force on the Impact of the Affordable Housing Credit Improvement Act; H.R. 2573/S. 1136, Affordable Housing Credit Improvement Act of 2021; H.R. 2143/S. 98, Neighborhood Homes Investment Act; H.R. 3680, Promoting Affordable Housing Near Transit Act; H.R. 816, Restoring Communities Left Behind Act; H.R. 1483, Revitalizing Economies, Housing, And Businesses (REHAB) Act of 2021; H.R. 1360, American Dream Down Payment Act of 2021; S. 1820, Choice in Affordable Housing Act of 2021; H.R. 1728, Strategy and Investment in Rural Housing Preservation Act of 2021; S. 2256, Charitable Conservation Easement Program Integrity Act of 2021; Housing tax credits; Community Development Block Grant program; Surface Transportation Black Grant program; Accessory Dwelling Units; Appointing Solomon Greene to the Office of Policy Development and Research at the Department of Housing and Urban Development; FY23 Appropriations; H.R. 2543, Federal Reserve Racial and Economic Equity Act; H.R. 4759/S. 2511, Revitalizing Downtowns Act; H.R. 7078, LIHTC Financing Enabling Long-term Investment in Neighborhood Excellence (LIFELINE) Act; S. 4485, Fair Housing Improvement Act of 2022; H.R. 5756, Portal for Appraisal Licensing Act of 2021; S. 4062, Helping Open Underutilized Space to Ensure Shelter (HOUSES) Act of 2022.
Client expense: $140,000 · Firm income: Not reported
Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, SENATE
2022 · fourth_quarter · Banking
S.2417, Credit Access and Inclusion; provisions pertaining to consumer credit, alternative data and financial inclusion. H.R.4120, Comprehensive Credit Reform Act; provisions pertaining to consumer credit. Issues pertaining to consumer finance, consumer credit, buy now pay later lending, and treatment of medical debt in credit reporting. S.1838, Building Credit Access for Veterans Act, issues pertaining to alternative data and credit reporting. H.R.7526, Servicemembers' Credit Monitoring Enhancement Act, issues pertaining to credit monitoring. H.R.6814 Small Business Fair Debt Collection Protection Act, issues pertaining to fair debt collection. National Credit Reporting Agency Act, issues pertaining to credit reporting. H.R.2543, Federal Reserve Racial and Economic Equity Act, issues pertaining to alternative data in mortgage underwriting, negative information on credit reports, medical debt, and credit checks for employment. H.R.8985 Credit Access and Inclusion Act, issues pertaining to credit reporting . McHenry GLBA Modernization Proposal.
Client expense: $430,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2022 · fourth_quarter · Financial Institutions/Investments/Securities
H.R. 935/S. 3391, Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2021 H.R. 1087, Shareholder Political Transparency Act of 2021 H.R. 1187, Corporate Governance Improvement and Investor Protection Act H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 1602, Eliminate Barriers to Innovation Act of 2021 H.R. 2025/S. 840, To amend title 28, United States Code, to increase transparency and oversight of third-party litigation funding in certain actions, and for other purposes H.R. 2516, Promoting Diversity and Inclusion in Banking Act of 2021 H.R. 2543, Federal Reserve Racial and Economic Equity Act H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2570, Climate Risk Disclosure Act of 2021 H.R. 2620, Investor Choice Act of 2021 H.R. 2990/S. 3931, Gig Worker Equity Compensation Act H.R. 3007, Disclosure of Tax Havens and Offshoring Act H.R. 3448/S. 4992, Helping Startups Continue to Grow Act H.R. 3454, Modernizing Disclosures for Investors Act H.R. 3843, Merger Filing Fee Modernization Act of 2022 H.R. 4227/S. 3914, Developing and Empowering our Aspiring Leaders Act H.R. 4277, Overdraft Protection Act of 2021 H.R. 4345, Financial Services and General Government Appropriations Act, 2022 H.R. 4521, America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength (America COMPETES) Act of 2022, including provisions related to House Amendment 218 H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate (LIBOR) Act of 2021 H.R. 4773, Consumer Financial Protection Commission Act H.R. 5128/S. 3503, Expanding Access to Capital for Rural Job Creators Act H.R. 5525, Establishing New Authorities for Businesses Laundering and Enabling Risks to Security (ENABLERS) Act H.R. 5586/S. 3056, Prohibiting IRS Financial Surveillance Act H.R. 5598/S. 3961, Access to Small Business Investor Capital Act H.R. 5648/S. 3022, Stop Wall Street Looting Act H.R. 5795/S. 3097, Main Street Growth Act H.R. 5910, Holding SPACs Accountable Act of 2021 H.R. 5911, Fair Hiring in Banking Act H.R. 7151, Ensuring Sound Guidance Act H.R. 7900, National Defense Authorization Act for Fiscal Year 2023 H.R. 7977, Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 8254/S. 4685, Financial Services and General Government Appropriations Act, 2023 H.R. 8521, Investor Democracy is Expected (INDEX) Act S. 479, Lifting Our Communities through Advance Liquidity for (LOCAL) Infrastructure Act S. 2417, Credit Access and Inclusion Act of 2021 S. 2508, Veterans and Consumers Fair Credit Act S. 3410, The Consumer Protection and Due Process Act S. 3755, Arbitration Fairness for Consumers Act S. 3921, Equal Opportunity for all Investors Act S. 3923, Dodd-Frank Material Disclosure Improvement Act S. 3930, Administrative Enforcement Fairness Act of 2022 S. 3939, Small Entrepreneurs' Empowerment and Development (SEED) Act of 2022 S. 3967, Improving Crowdfunding Opportunities Act S. 3976, Expanding American Entrepreneurship Act S. 4241, Investor Democracy is Expected (INDEX) Act S. 5005, Mandatory Materiality Requirement Act of 2022 Draft legislation titled Jumpstart our Business Startups (JOBS) Act 4.0 of 2022 Draft legislation titled Mandatory Materiality Requirement Act of 2022 Potential legislation to foster economic growth and job creation through capital formation Potential legislation to further economic growth through environmental, social, and governance factors Potential legislation to make changes to the Exchange Act Rule 14a-8 shareholder proposal process Potential legislation to hold proxy voting advice businesses accountable Potential legislation to require the SEC to consider additional standards in the rulemaking process Potential legislation to study the term small entity Potential legislation regarding a new regulatory framework for stablecoins Potential legislation dealing with third party litigation financing and lawsuit lending SEC Money Market Fund Reforms (86 Fed. Reg. 7,248, December 15, 2021) Proposed Rule, Securities and Exchange Commission; Prohibition Against Fraud, Manipulation, or Deception in Connection with Security-Based Swaps, Prohibition against Undue Influence over Chief Compliance Officers, Position Reporting of Large Security-Based Swap Positions (87 Fed. Reg. 6,652-6,706, February 4, 2022) Proposed rule on Enhancement and Standardization of Climate-Related Disclosures for Investors (87 Fed. Reg. 21,334-21,473, April 11,2022) Proposed Rule, Securities and Exchange Commission; Enhanced Disclosures by Certain Investment Advisers and Investment Companies About Environmental, Social, and Governance Investment Practices (87 Fed. Reg. 36,654-36,761, June 17, 2022) Proposed Rule, Securities and Exchange Commission; Investment Company Names (87 Fed. Reg. 36,594-36,651, June 17,2022) Request for Comment on Certain Information Providers Acting as Investment Advisers; Securities and Exchange Commission (87 Fed. Reg. 37,254-37,262, June 22, 2022) Request for Comment, Bureau of Consumer Financial Protection; Agency Information Collection Activities, Report of Terms of Credit Card Plans (Form FR 2572) and Consumer and College Credit Card Agreements (87 Fed. Reg. 50,851-50,852, August 18, 2022) Proposed Rule, Commodity Futures Trading Commission and Securities and Exchange Commission; Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers (87 Fed. Reg. 53,832-53,985 , September 1, 2022) Proposed Rule, Securities and Exchange Commission; Resubmission of Comments and Reopening of Comment Periods for Several Rulemaking Releases Due to a Technological Error is Receiving Certain Comments (87 Fed. Reg. 63,016-63,017, October 18, 2022) SEC Proposed Rule on ESG Disclosures for Investment Advisers and Investment Companies (87 Fed. Reg. 36,654 - 36,761, August 16, 2022) Request for Comment, Securities and Exchange Commission; Draft 2022-2026 Strategic Plan for Securities and Exchange Commission (87 Fed. Reg. 53,040, August 30, 2022) Request for Information, Commodity Futures Trading Commission; Climate-Related Financial Risk (87 Fed. Reg. 34,856-34,862, June 8, 2022) Various issues relating to SEC Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; Public Company Accounting Oversight Board (PCAOB); CFTCs de minimis Exception for Swap Dealers; Securities and Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); qualified mortgage definition under the Truth in Lending Act (P.L. 90-321) (Regulation Z); Financial Stability Oversight Council and the designation of Nonbank Financial Firms as systemically important; Federal Reserve Systems Large Institution Supervision Coordinating Committee; potential housing finance reform legislation; enforcement of Securities and Exchange Commission penalties; potential repeal of the State and Local Tax (SALT) Cap; federal interest rate authority; Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) reform; electronic consent-based SSN Verification Service (eCBSV); environmental, social, and governance (ESG) enforcement; information Collection under the Community Reinvestment Act (CRA); potential Financial Transaction Tax (FTT); potential Treasury Department proposal relating to tax reporting by banks; investment company cross trading; potential money market fund reform measures; resolutions to establish task forces on Artificial Intelligence and Financial Technology in the House Committee on Financial Services; transition to the secured overnight financing rate; implementation of SEC Rule 15c2-11; Department of Labor fiduciary advice exemption: PTE 2020-02; benefits of risk-based pricing; mobile disclosures; Federal Trade Commission issues: Freedom of Information Act Requests, Penalty Offense Authority, Zombie Voting, and overall direction of the Commission under Chair Lina Khan; Tax Reporting Proposal by the Department of the Treasury related to a $600 or more annual account threshold; Amendment to the FY22 National Defense Authorization Act related to credit reporting; Climate-Related Financial Risk Management for Large Banks; House Committee on Financial Services request for information related to Russia sanctions; Consumer Financial Protection Bureau (CFPB) regulatory sandbox for disclosures; CFPB Policy Fellowship program; CFPB amendment of its Supervision and Examination Manual; CFPB conflation of Distinct Statutory Concepts of Unfairness and Discrimination Promoting the importance of appropriate length of SEC Comment Periods; Internal Revenue Service; Priority Guidance Plan; Compliance Assistance Release, Department of Labor; 401(k) Plan Investments in Cryptocurrencies Request for Information, Consumer Financial Protection Bureau; Fees Imposed by Providers of Consumer Financial Products or Services; Notice of Inquiry, Federal Communications Commission; In the Matter of Implementing the Infrastructure Investment and Jobs Act: Prevention and Elimination of Digital Discrimination; (GN Docket No. 22-69); Consumer Financial Protection Bureau; Enhancing Public Data on Auto Lending; Document ID CFPB-2022-0075-0001 (November 17, 2022); Proposed Rule, Securities and Exchange Commission; Open-End Fund Liquidity Risk Management Programs and Swing Pricing, Form N-PORT; Outsourcing by Investment Advisers (File Nos. S7-26-22, S7-25-22; RIN 3325-AM98; RIN 3235-AN18, November 2, 2022); EU sustainable finance action plan and incorporating ESG factors into financial services; EU requirements for supply chain due diligence and disclosure; EU review of Alternative Investment Fund Managers Directive; EU review of prudential regime for investment firms; implementation and enforcement of Regulation Best Interest by the Securities and Exchange Commission; changes in the enforcement policies of the Securities and Exchange Commission; activity of the Financial Stability Oversight Council and recommendations on macro-prudential regulation; clarification in the regulatory treatment of digital assets by the Securities and Exchange Commission and the Commodity Futures Trading Commission; EU Money Market Fund Regulation, legislative review; electronic delivery of certain investment documents and disclosures; Financial Stability Board recommendations on money market fund reform; IOSCO recommendations on sustainability-related practices, polices, procedures, and disclosure in asset management; Office of Financial Research (OFR) discussions on FSOC Report on Climate-Related Financial Risk; Written responses regarding requests for comment resulting from the March 9, 2022 Executive Order on Ensuring Responsible Development of Digital Assets; FinCEN Implementation of the Beneficial Ownership Requirements of the Corporate Transparency Act (P.L. 116-283)
Client expense: $20,990,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
2022 · fourth_quarter · Banking
Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2561, Promoting Access to Capital in Unbanked Communities Act of 2021 S. 910, SAFE Banking Act 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." H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate LIBOR Act H.R. 5189, Member Business Loan Expansion Act S. 2508, Veterans and Consumer Fair Credit Act Perlmutter Amendment (H.Amdt.97) to H.R. 4350, National Defense Authorization Act of 2022 H.R. 2989, Financial Transparency Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act Coin Circulation S. 3779, Adjustable Interest Rate LIBOR Act H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking. H.R. 2543, Federal Reserve Racial and Economic Equity Act UDAAP Supervisory Policies and Adjudication Procedures Issues impacting the modernization of the Community Reinvestment Act Deposit Insurance Assessment Rates S.4674, Credit Card Competition Act H.R. 8874, Credit Card Competition Act H.R. 8485, Expanding Access to Credit through Consumer-Permissioned Data Act S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes
Client expense: $2,840,000 · Firm income: Not reported
Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2022 · fourth_quarter · Financial Institutions/Investments/Securities
General issues related to consumer lending. H.R.5974/S.2508 - Veterans and Consumers Fair Credit Act. H.R.2543 - Federal Reserve Racial and Economic Equity Act. H.R.5912 - Close the ILC Loophole Act.
Client expense: Not reported · Firm income: $60,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2022 · fourth_quarter · Financial Institutions/Investments/Securities
Legislative proposals impacting banking services for financial services providers; Payday, Vehicle Title, and Certain High-Cost Installment Loans; Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday and auto title lending, and regulatory process; FY2023 National Defense Authorization Act (H.R.7900, S.4543); H.R.4395, Payment Choice Act of 2021; S.2349, Protecting Consumers from Unreasonable Credit Rates Act of 2021; S.2508/H.R.5974, Veterans and Consumers Fair Credit Act; H.R.2543, Federal Reserve Racial and Economic Equity Act.
Client expense: Not reported · Firm income: $60,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2022 · fourth_quarter · Banking
H.R. 1996 SAFE Banking Act H.R. 2543 Federal Reserve Racial and Economic Equity Act, Credit Union Provisions & Community Bank Amendment H.R. 2561 Promoting Access to Capital in Underbanked Communities Act of 2021 H.R. 2617 Consolidated Appropriations Act, opposed amendments related to Credit Card Competition Act H.R. 4277 Overdraft Protection Act H.R. 4345 FY 2022 Financial Services and General Government Appropriation - Postal Banking Pilot Program H.R. 5886 Prohibit IRS Financial Surveillance Act H.R. 5912 Close ILC Loophole Act H.R. 6037 Prohibit SBA 7(a) Direct Lending H.R. 6054 Small Business Lending Disclosure Act H.R. 6732 Small LENDER Act H.R. 6814 Small Business Fair Debt Collection Practices Act H.R. 7003 Expanding Financial Access for Underserved Communities Act H.R. 7412 Transparency in CFPB Cost-Benefit Analysis Act H.R. 7768 Farm Credit Administration Independence Authority Act H.R. 7776 National Defense Authorization Act, master accounts and services database H.R. 7900 National Defense Authorization Act, opposed amendments related to Credit Card Competition Act H.R. 8152 American Data Privacy and Protection Act H.R. 8443 Making the CFPB Accountable Act H.R. 8833 The Making Communities Stronger Through the Community Reinvestment Act H.R. 8874 Credit Card Competition Act H.R. 8950 the Digital Commodities Consumer Protection Act of 2022 H.R. 9599 Consumer Information Notification Requirement Act S. 910 SAFE Banking Act S. 1684 Federal Home Loan Banks Mission Implementation Act S. 3056 Prohibit IRS Financial Surveillance Act S. 3715 E-Sign Modernization Act S. 3954 Ban CBDC S. 3970 Stablecoin Transparency Act S. 4004 Small LENDER Act S. 4356 Lummis-Gillibrand Responsible Financial Innovation Act S. 4522 Transparency in CFPB Cost-Benefit Analysis Act S. 4674 Credit Card Competition Act S. 4698 Improving Cybersecurity of Credit Unions Act S. 4831 No CBDC Act S. 5189 Close the Shadow Banking Loophole Act S. 5340 Stablecoin TRUST Act of 2022 S. 5341 A bill to amend the Federal Reserve Act to provide greater accountability to the Federal Reserve System Bank Merger Policy BankOn accounts Banking Services Fees Cannabis Banking CDFI Certification Central Bank Digital Currency Climate Risk Disclosure Requirements Climate-Related Financial Regulation Community Bank Access to Capital Community Banks on Military Bases Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Consolidated Appropriations Act, supported inclusion of the SAFE Banking Act; opposed inclusion of Credit Card Competition Act Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Cybersecurity Requirements Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Supplemental Capital Cryptocurrency Customer Data Access, Implementation of Dodd Frank Act Section 1033 Cybersecurity Data Privacy Discussion Draft Data Security, Breaches and Privacy De Novo Bank Formation Dodd Frank Act 1071- Small Business Loan Data Collection Digital Assets Regulation Durbin Amendment on Interchange; Extension to Credit Cards FDIC Deposit Insurance Assessments FDIC Premium Increases FDIC Supervisory Appeals Review Committee and Policy FHFA Capital Rules Financial Data Privacy Discussion Draft Fintech Regulatory Requirements Fintech/Banking Relationships Flood Insurance Reauthorization Industrial Loan Corporation Loophole Reforms/ Rakuten (ILC) et al, Deposit Insurance Applications Interchange Minority Depository Institutions Issues National Defense Authorization Act, Report Language on Financial Institution leases on military bases National Defense Authorization Act, Supported Inclusion of the SAFE Banking Act; Opposed Inclusion of Credit Card Competition Act as an Amendment Overdraft Fees Overdraft Protection P2P Payment Applications Fraud Postal Banking SAFE Banking Act, support for inclusion in America COMPETES Act Conference SBA 7(a) Loan Program Funding and Terms SBA Direct 7(a) Direct Lending Secure Notarization Small Business Loan Data Collection--CFPB Implementation of Dodd-Frank Act Section 1071 Stablecoins Stablecoin Innovation and Protection Act of 2022 (draft) Stablecoin Legislation - Waters-McHenry Discussion Draft Stablecoin TRUST Act (draft)
Client expense: $1,303,790 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of
2022 · fourth_quarter · Banking
H.R. 1319, American Rescue Plan Act; H.R. 1417 - regarding credit union member business lending. Pay Check Protection Program implementation; credit union field of membership issues including maturity limits for federal credit unions; Fair lending; cannanis banking; Prompt Corrective Action for credit unions and capital reform. Community Development Finanical Institutions. Nominations for the CFPB's Credit Union Advisory Council. Expanding Finanical Access to Underserved Communities Act. Central Liquidity Enhancement Act. H.R. 3958, H.R. 2311, S.1767, H.R. 5189, S.762. H.R.7003 The Expanding Financial Acess for Underserved Communities Act, H.R. 6889 and S. 4325, The Credit Union Board Modernization Act. H.R. 2543. NCUA's Central liquidty facility.
Client expense: $110,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), SENATE, Treasury, Dept of
2022 · third_quarter · Banking
H.R. 1996 SAFE Banking Act H.R. 2543 Federal Reserve Racial and Economic Equity Act, Credit Union Provisions & Community Bank Amendment Amendment #6 to H.R. 2543, to repeal Section 1071 of the Dodd-Frank Act Sec. 521, 522, 523 & 524 of H.R.2543 - Federal Reserve Racial and Economic Equity Act H.R. 2561 Promoting Access to Capital in Underbanked Communities Act of 2021 H.R. 3009 Improving Language Access in Mortgage Servicing H.R. 4277 Overdraft Protection Act H.R. 4345 FY 2022 Financial Services and General Government Appropriation - Postal Banking Pilot Program H.R. 4590 Promoting New and Diverse Depository Institutions Act H.R. 5376 Inflation Reduction Act of 2022 (Build Back Better) H.R. 5886 Prohibit IRS Financial Surveillance Act H.R. 5912 Close ILC Loophole Act H.R. 6037 Prohibit SBA 7(a) Direct Lending H.R. 6054 Small Business Lending Disclosure Act H.R. 6732 Small LENDER Act H.R. 6739 Business Loan Privacy Act H.R. 6802 Prevent Racial Profiling in Lending Act H.R. 6814 Small Business Fair Debt Collection Practices Act H.R. 6889 The Credit Union Board Modernization Act H.R. 7003 Expanding Financial Access for Underserved Communities Act H.R. 7412 Transparency in CFPB Cost-Benefit Analysis Act H.R. 7768 Farm Credit Administration Independence Authority Act H.R. 8152 American Data Privacy and Protection Act H.R. 8443 Making the CFPB Accountable Act H.R. 8833 The Making Communities Stronger Through the Community Reinvestment Act H.R. 8874 Credit Card Competition Act H.R. 8950 the Digital Commodities Consumer Protection Act of 2022 S. 910 SAFE Banking Act S. 1684 Federal Home Loan Banks Mission Implementation Act S. 3056 Prohibit IRS Financial Surveillance Act S. 3382 Protecting Access to Credit for Small Businesses Act S. 3715 E-Sign Modernization Act S. 3954 Ban CBDC S. 4004 Small LENDER Act S. 4356 Lummis-Gillibrand Responsible Financial Innovation Act S. 4522 Transparency in CFPB Cost-Benefit Analysis Act S. 4674 Credit Card Competition Act S. 4831 No CBDC Act Amendments 69 and 70 to FY2023 FSGG Appropriations Bill (Postal banking) Bank Merger Policy BankOn accounts Banking Services Fees Cannabis Banking Central Bank Digital Currency Climate Risk Disclosure Requirements Climate-Related Financial Regulation Community Bank Access to Capital Community Banks on Military Bases Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Consumer Financial Protection Bureau, report of financial services in rural America Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Cybersecurity Requirements Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Supplemental Capital Cryptocurrency Customer Data Access, Implementation of Dodd Frank Act Section 1033 Cybersecurity Data Privacy Discussion Draft Data Security, Breaches and Privacy De Novo Bank Formation Dodd Frank Act 1071- Small Business Loan Data Collection Digital Assets Regulation Durbin Amendment on Interchange; Extension to Credit Cards FDIC Deposit Insurance Assessments FDIC Premium Increases FDIC Supervisory Appeals Review Committee and Policy Financial Data Privacy Discussion Draft 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 Minority Depository Institutions Issues National Defense Authorization Act, Opposition to Inclusion of Credit Card Competition Act as an Amendment National Defense Authorization Act, Report Language on Financial Institution leases on military bases OCC Proposed Payments Charter Overdraft Fees Overdraft Protection P2P Payment Applications Fraud Postal Banking Protecting Consumers from Payment Scams Act (draft) SAFE Banking Act, support for inclusion in America COMPETES Act Conference SBA 7(a) Loan Program Funding and Terms SBA Direct 7(a) Direct Lending Secure Notarization Small Business Loan Data Collection--CFPB Implementation of Dodd-Frank Act Section 1071 Stablecoins Stablecoin Innovation and Protection Act of 2022 (draft) Stablecoin Legislation - Waters-McHenry Discussion Draft Stablecoin TRUST Act (draft) Unfair, deceptive, or abusive acts and practices (UDAAP)
Client expense: $718,825 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
2022 · third_quarter · Financial Institutions/Investments/Securities
General issues related to consumer lending. H.R.5974/S.2508 - Veterans and Consumers Fair Credit Act. H.R.4395 - Payment Choice Act of 2021. H.R.2543 - Federal Reserve Racial and Economic Equity Act. H.R.5912 - Close the ILC Loophole Act.
Client expense: Not reported · Firm income: $60,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2022 · third_quarter · Housing
H.R. 2483/S. 3237, Build More Housing Near Transit Act of 2021; H.R. 2126/S. 902, Housing Supply and Affordability Act; H.R. 3198/S. 1614, Yes in my Backyard Act; H.R. 6307, Tiny Homes for Homeless Veterans; Housing, Opportunity, Mobility, and Equity (HOME) Act; Build Back Better; S. 768, Better Planning and Land-Use for Accessible Neighborhoods Act; H.R. 1615, Maximizing Our Redevelopment and Efficiency for Transit Oriented Development (More TOD) Act of 2021; Task Force on the Impact of the Affordable Housing Credit Improvement Act; H.R. 2573/S. 1136, Affordable Housing Credit Improvement Act of 2021; H.R. 2143/S. 98, Neighborhood Homes Investment Act; H.R. 3680, Promoting Affordable Housing Near Transit Act; H.R. 816, Restoring Communities Left Behind Act; H.R. 1483, Revitalizing Economies, Housing, And Businesses (REHAB) Act of 2021; H.R. 1360, American Dream Down Payment Act of 2021; S. 1820, Choice in Affordable Housing Act of 2021; H.R. 1728, Strategy and Investment in Rural Housing Preservation Act of 2021; S. 2256, Charitable Conservation Easement Program Integrity Act of 2021; Housing tax credits; Community Development Block Grant program; Surface Transportation Black Grant program; Accessory Dwelling Units; Appointing Solomon Greene to the Office of Policy Development and Research at the Department of Housing and Urban Development; FY23 Appropriations; H.R. 2543, Federal Reserve Racial and Economic Equity Act; H.R. 4759/S. 2511, Revitalizing Downtowns Act; H.R. 7078, LIHTC Financing Enabling Long-term Investment in Neighborhood Excellence (LIFELINE) Act; S. 4485, Fair Housing Improvement Act of 2022; H.R. 5756, Portal for Appraisal Licensing Act of 2021; S. 4062, Helping Open Underutilized Space to Ensure Shelter (HOUSES) Act of 2022.
Client expense: $140,000 · Firm income: Not reported
Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, SENATE
2022 · third_quarter · Housing
H.R. 2543 Financial Services Racial Equity, Inclusion, and Economic Justice Act H.R. 2553 Real Estate Valuation Fairness and Improvement Act of 2021 H.R. 3009 Improving Language Access in Mortgage Servicing Act H.R. 3172 HELPER Act H.R. 4155 Green Neighborhoods Act of 2021 H.R. 4495 Downpayment Toward Equity Act of 2022 H.R. 4657 Veteran Home Energy Savings Act H.R. 5915 FHA Fairness Act H.R. 7049 Mortgage Borrower Protection Act of 2022 H.R. 7735 Improving Access to the VA Home Loan Benefit Act of 2022 S. 4208 Improving Access to the VA Home Loan Benefit Act of 2022 S. 1838 Building Credit Access for Veterans Act of 2022 S. 3788 Housing for All Act of 2022 S. 3941 Housing Supply Expansion Act H.R. 8235 Housing Supply Expansion Act S. 4445 Affordable Housing Bond Enhancement Act S.4737 Housing Market Transparency Act S.4872 Strategy and Investment in Rural Housing Preservation Act of 2022 FHA MIP reduction, servicing standards, and other FHA program issues. GNMA Issuer Eligibility standards FHFA Capital and Liquidity Standards for IMBs GSE condo project guidelines
Client expense: $520,000 · Firm income: Not reported
Government targets: Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE
2022 · third_quarter · Banking
H.R. 4277 S.2677 Would implement highly prescriptive disclosures, limitations, and prohibitions on a financial products that are in high demand by consumers who can opt- out of services H.R. 6889 S. 4325 Allows credit union boards to meet every other month rather than every month provided that the credit union is in good standing H.R. 1996 S. 910 Allows financial institutions to provide banking services to marijuana businesses in states where it has been legalized H.R. 8152 Would implement one national standard for all holders of financial information including merchants. H.R. 2543 S.1327 add underserved areas to the field of membership exempt business loans made to businesses located in underserved areas from the member business lending cap
Client expense: Not reported · Firm income: $9,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2022 · third_quarter · Financial Institutions/Investments/Securities
H.R. 935, Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2021 H.R. 1087, Shareholder Political Transparency Act of 2021 H.R. 1187, Corporate Governance Improvement and Investor Protection Act H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 1602, Eliminate Barriers to Innovation Act of 2021 H.R. 2025/S. 840, To amend title 28, United States Code, to increase transparency and oversight of third-party litigation funding in certain actions, and for other purposes H.R. 2516, Promoting Diversity and Inclusion in Banking Act of 2021 H.R. 2543, Federal Reserve Racial and Economic Equity Act H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2570, Climate Risk Disclosure Act of 2021 H.R. 2620, Investor Choice Act of 2021 H.R. 3007, Disclosure of Tax Havens and Offshoring Act H.R. 3448, Helping Startups Continue to Grow Act H.R. 3454, Modernizing Disclosures for Investors Act H.R. 3843, Merger Filing Fee Modernization Act of 2022 H.R. 4277, Overdraft Protection Act of 2021 H.R. 4345, Financial Services and General Government Appropriations Act, 2022 H.R. 4521, America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength (America COMPETES) Act of 2022, including provisions related to House Amendment 218 H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate (LIBOR) Act of 2021 H.R. 4773, Consumer Financial Protection Commission Act H.R. 5586/S. 3056, Prohibiting IRS Financial Surveillance Act H.R. 5648/S. 3022, Stop Wall Street Looting Act H.R. 5910, Holding SPACs Accountable Act of 2021 H.R. 5911, Fair Hiring in Banking Act H.R. 7151, Ensuring Sound Guidance Act H.R. 7900, National Defense Authorization Act for Fiscal Year 2023 H.R. 7977, Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 8254/S. 4685, Financial Services and General Government Appropriations Act, 2023 H.R. 8521, Investor Democracy is Expected (INDEX) Act S. 479, Lifting Our Communities through Advance Liquidity for (LOCAL) Infrastructure Act S. 2417, Credit Access and Inclusion Act of 2021 S. 2508, Veterans and Consumers Fair Credit Act S. 2621, Modernization of Derivatives Tax Act of 2021 S. 3410, The Consumer Protection and Due Process Act S. 3755, Arbitration Fairness for Consumers Act S. 3844, Economic Continuity and Stability Act S. 3914, Developing and Empowering our Aspiring Leaders Act of 2022 S. 4241, Investor Democracy is Expected (INDEX) Act Draft legislation titled Jumpstart our Business Startups (JOBS) Act 4.0 of 2022 Draft legislation titled Mandatory Materiality Requirement Act of 2022 Potential legislation to foster economic growth and job creation through capital formation Potential legislation to further economic growth through environmental, social, and governance factors Potential legislation to make changes to the Exchange Act Rule 14a-8 shareholder proposal process Potential legislation to hold proxy voting advice businesses accountable Potential legislation to expressing a sense of Congress reaffirming the Supreme Court materiality standard Potential legislation to require the SEC to consider additional standards in the rulemaking process Potential legislation to study the term small entity Potential legislation regarding a new regulatory framework for stablecoins Potential legislation dealing with third party litigation financing and lawsuit lending Potential legislation dealing with securities litigation Nomination of Mark Uyeda to be Commissioner of the U.S. Securities and Exchange Commission (SEC) Proposed rule regarding SEC Enhanced Reporting of Proxy Votes by Registered Management Investment Companies; Reporting of Executive Compensation Votes by Institutional Investment Managers Proposed Rule (86 Fed. Reg. 57,478-57,524, October 15, 2021) Proposed rule regarding Position Reporting of Large Security-Based Swap Positions (87 Fed. Reg. 6,652-6,706, December 15, 2021) SEC Money Market Fund Reforms (86 Fed. Reg. 7,248, December 15, 2021) Proposed rules regarding amendments to Form PF (87 Fed. Reg. 9,106-9,235, January 26, 2022) Proposed rule regarding Share Repurchase Disclosure Modernization (87 Fed. Reg. 8,443-8,472, February 15, 2022) Proposed Rule, Securities and Exchange Commission; Prohibition Against Fraud, Manipulation, or Deception in Connection with Security-Based Swaps, Prohibition against Undue Influence over Chief Compliance Officers, Position Reporting of Large Security-Based Swap Positions (87 Fed. Reg. 6,652-6,706, February 4, 2022) Proposed rule on Enhancement and Standardization of Climate-Related Disclosures for Investors (87 Fed. Reg. 21,334-21,473, April 11,2022) Proposed Rule, Securities and Exchange Commission; Enhanced Disclosures by Certain Investment Advisers and Investment Companies About Environmental, Social, and Governance Investment Practices (87 Fed. Reg. 36,654-36,761, June 17, 2022) Proposed Rule, Securities and Exchange Commission; Investment Company Names (87 Fed. Reg. 36,594-36,651, June 17,2022) Proposed Rule, Securities and Exchange Commission; Share Repurchase Disclosure Modernization (87 Fed. Reg. 8,443-8,472, April 1, 2022) Proposed Rule, Securities and Exchange Commission; Substantial Implementation, Duplication, and Resubmission of Shareholder Proposals Under Exchange Act Rule 14a-8 (87 Fed. Reg. 45,052-45,075. July 27, 2022) Request for Comment on Certain Information Providers Acting as Investment Advisers; Securities and Exchange Commission (87 Fed. Reg. 37,254-37,262, June 22, 2022) Request for Comment, Bureau of Consumer Financial Protection; Agency Information Collection Activities, Report of Terms of Credit Card Plans (Form FR 2572) and Consumer and College Credit Card Agreements (87 Fed. Reg. 50,851-50,852, August 18, 2022) Advance Notice of Proposed Rulemaking, Bureau of Consumer Financial Protection; Credit Card Late Fees and Late Payments (87 Fed. Reg. 42,662, July 18, 2022) Joint Notice of Proposed Rulemaking, Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, Federal Reserve System; Community Reinvestment Act (87 Fed. Reg. 33,884-34,066, June 3, 2022) Request for Comments, Department of the Treasury; Ensuring Responsible Development of Digital Assets (87 Fed. Reg. 40,881-40,883, July 8, 2022) Request for Comment, International Trade Administration; Developing a Framework on Competitiveness of Digital Asset Technologies (87 Fed. Reg. 30450- 30452, May 19, 2022) Various issues relating to SEC Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; Public Company Accounting Oversight Board (PCAOB); CFTCs de minimis Exception for Swap Dealers; Securities and Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); qualified mortgage definition under the Truth in Lending Act (P.L. 90-321) (Regulation Z); Financial Stability Oversight Council and the designation of Nonbank Financial Firms as systemically important; Federal Reserve Systems Large Institution Supervision Coordinating Committee; potential housing finance reform legislation; enforcement of Securities and Exchange Commission penalties; potential repeal of the State and Local Tax (SALT) Cap; federal interest rate authority; Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) reform; electronic consent-based SSN Verification Service (eCBSV); environmental, social, and governance (ESG) enforcement; information Collection under the Community Reinvestment Act (CRA); potential Financial Transaction Tax (FTT); potential Treasury Department proposal relating to tax reporting by banks; investment company cross trading; potential money market fund reform measures; resolutions to establish task forces on Artificial Intelligence and Financial Technology in the House Committee on Financial Services; transition to the secured overnight financing rate; implementation of SEC Rule 15c2-11; Department of Labor fiduciary advice exemption: PTE 2020-02; benefits of risk-based pricing; mobile disclosures; Federal Trade Commission issues: Freedom of Information Act Requests, Penalty Offense Authority, Zombie Voting, and overall direction of the Commission under Chair Lina Khan; Tax Reporting Proposal by the Department of the Treasury related to a $600 or more annual account threshold; Amendment to the FY22 National Defense Authorization Act related to credit reporting; Climate-Related Financial Risk Management for Large Banks; House Committee on Financial Services request for information related to Russia sanctions; CFPB Policy Fellowship program; CFPB amendment of its Supervision and Examination Manual; CFPB conflation of Distinct Statutory Concepts of Unfairness and Discrimination; Promoting the importance of appropriate length of SEC Comment Periods; Internal Revenue Service; Priority Guidance Plan; Compliance Assistance Release, Department of Labor; 401(k) Plan Investments in Cryptocurrencies Request for Information, Consumer Financial Protection Bureau; Fees Imposed by Providers of Consumer Financial Products or Services; Notice of Inquiry, Federal Communications Commission; In the Matter of Implementing the Infrastructure Investment and Jobs Act: Prevention and Elimination of Digital Discrimination; (GN Docket No. 22-69); EU sustainable finance action plan and incorporating ESG factors into financial services; EU review of Alternative Investment Fund Managers Directive; EU review of prudential regime for investment firms; implementation and enforcement of Regulation Best Interest by the Securities and Exchange Commission; changes in the enforcement policies of the Securities and Exchange Commission; activity of the Financial Stability Oversight Council and recommendations on macro-prudential regulation; clarification in the regulatory treatment of digital assets by the Securities and Exchange Commission and the Commodity Futures Trading Commission; implementation and enforcement of proxy advisory firm regulations finalized in 2020; implementation and enforcement of SEC 14a-8 shareholder proposal process reforms finalized in 2020; EU Money Market Fund Regulation, legislative review; electronic delivery of certain investment documents and disclosures; implementation of beneficial ownership reporting requirements under the National Defense Authorization Act FY2021 (P.L. 116-283); implementation of the Social Security Administrations Electronic Consent Based Social Security Number Verification System Service; Financial Stability Board recommendations on money market fund reform; IOSCO recommendations on sustainability-related practices, polices, procedures, and disclosure in asset management; Office of Financial Research (OFR) discussions on FSOC Report on Climate-Related Financial Risk; staff legal guidance at the SEC concerning no-action letters on shareholder proposals with broad societal impact (Staff Legal Bulletin 14L-CF); SEC Reforms to regulations related to Cybersecurity Disclosures; SEC Reforms to regulations related to Human Capital Management Disclosures; SEC Reforms to regulations related to proxy voting advice businesses; SEC request for information on digital engagement practices; Written responses regarding requests for comment resulting from the March 9, 2022 Executive Order on Ensuring Responsible Development of Digital Assets; SEC Proposed Rule amending 10b5-1; SEC Proposed Rule on Private Fund Advisers; Documentation of Registered Investment Adviser Compliance Reviews; SEC Amended Rule 15c2-11, applicability to 144A securities; SEC Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors; SEC Substantial Implementation, Duplication, and Resubmission of Shareholder Proposals Under Exchange Act Rule 14a-8; PCAOB 2022-2026 Draft Strategic Plan; SEC FY 22-26 Strategic Plan; FinCEN Implementation of the Beneficial Ownership Requirements of the Corporate Transparency Act (P.L. 116-283)
Client expense: $23,940,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
2022 · third_quarter · Banking
S.2417, Credit Access and Inclusion; provisions pertaining to consumer credit, alternative data and financial inclusion. H.R.4120, Comprehensive Credit Reform Act; provisions pertaining to consumer credit. Issues pertaining to consumer credit, buy now pay later lending, and treatment of medical debt in credit reporting. S.1838, Building Credit Access for Veterans Act, issues pertaining to alternative data and credit reporting. H.R.7526, Servicemembers' Credit Monitoring Enhancement Act, issues pertaining to credit monitoring. H.R.6814 Small Business Fair Debt Collection Protection Act, issues pertaining to fair debt collection. H.R.4521, America COMPETES Act of 2022, provisions pertaining to Digital Identity, the INFORM Act, and SAFE banking. National Credit Reporting Agency Act, issues pertaining to credit reporting. H.R.2543, Federal Reserve Racial and Economic Equity Act, issues pertaining to alternative data in mortgage underwriting, negative information on credit reports, medical debt, and credit checks for employment. H.R.8985 Credit Access and Inclusion Act, issues pertaining to credit reporting .
Client expense: $530,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2022 · third_quarter · Financial Institutions/Investments/Securities
Legislative proposals impacting banking services for financial services providers; Payday, Vehicle Title, and Certain High-Cost Installment Loans; Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday and auto title lending, and regulatory process; FY2023 National Defense Authorization Act (H.R.7900, S.4543); H.R.4395, Payment Choice Act of 2021; S.2349, Protecting Consumers from Unreasonable Credit Rates Act of 2021; S.2508/H.R.5974, Veterans and Consumers Fair Credit Act; H.R.2543, Federal Reserve Racial and Economic Equity Act.
Client expense: Not reported · Firm income: $60,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2022 · third_quarter · Banking
The Financial Services Racial Equity Inclusion and Economic Justice Act (HR 2543) Community Reinvestment Act
Client expense: Not reported · Firm income: $30,000
Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of
2022 · third_quarter · Banking
Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2561, Promoting Access to Capital in Unbanked Communities Act of 2021 S. 910, SAFE Banking Act 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." H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate LIBOR Act H.R. 5189, Member Business Loan Expansion Act S. 2508, Veterans and Consumer Fair Credit Act Perlmutter Amendment (H.Amdt.97) to H.R. 4350, National Defense Authorization Act of 2022 H.R. 2989, Financial Transparency Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act Coin Circulation S. 3779, Adjustable Interest Rate LIBOR Act H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking. H.R. 2543, Federal Reserve Racial and Economic Equity Act UDAAP Supervisory Policies and Adjudication Procedures Issues impacting the modernization of the Community Reinvestment Act Deposit Insurance Assessment Rates S.4674, Credit Card Competition Act H.R. 8874, Credit Card Competition Act H.R. 8485, Expanding Access to Credit through Consumer-Permissioned Data Act S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes
Client expense: $2,870,000 · Firm income: Not reported
Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2022 · third_quarter · Economics/Economic Development
Extending and modifying the CDFI Bond Guarantee Program. Worked to advance the CDFI Bond Guarantee Program Improvement Act of 2022 (S.3441 and H.R.7733) and passed the House as part of the Financial Services Racial Equity, Inclusion, and Economic Justice Act (H.R.2543) on June 15, 2022.
Client expense: Not reported · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2022 · third_quarter · Banking
H.R. 1996 SAFE Banking Act H.R. 2543 Federal Reserve Racial and Economic Equity Act, Credit Union Provisions & Community Bank Amendment Amendment #6 to H.R. 2543, to repeal Section 1071 of the Dodd-Frank Act Sec. 521, 522, 523 & 524 of H.R.2543 - Federal Reserve Racial and Economic Equity Act H.R. 2561 Promoting Access to Capital in Underbanked Communities Act of 2021 H.R. 3009 Improving Language Access in Mortgage Servicing H.R. 4277 Overdraft Protection Act H.R. 4345 FY 2022 Financial Services and General Government Appropriation - Postal Banking Pilot Program H.R. 5376 The Build Back Better Act H.R. 5886 Prohibit IRS Financial Surveillance Act H.R. 5912 Close ILC Loophole Act H.R. 6037 Prohibit SBA 7(a) Direct Lending H.R. 6054 Small Business Lending Disclosure Act H.R. 6307 Protecting Access to Credit for Small Businesses Act H.R. 6732 Small LENDER Act H.R. 6739 Business Loan Privacy Act H.R. 6745 Ensuring Diversity in Community Banking Act H.R. 6802 Prevent Racial Profiling in Lending Act H.R. 6814 Small Business Fair Debt Collection Practices Act H.R. 7003 Expanding Financial Access for Underserved Communities Act H.R. 7022 Strengthening Cybersecurity Act H.R. 7412 Transparency in CFPB Cost-Benefit Analysis Act H.R. 7768 Farm Credit Administration Independence Authority Act H.R. 8152 American Data Privacy and Protection Act S. 910 SAFE Banking Act S. 1684 Federal Home Loan Banks Mission Implementation Act S. 3056 Prohibit IRS Financial Surveillance Act S. 3382 Protecting Access to Credit for Small Businesses Act S. 3409 A bill to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024, and for other purposes. S. 3441 CDFI Bond Guarantee Program Improvement Act S. 3715 E-Sign Modernization Act S. 3745 TAILOR Act S. 3954 Ban CBDC S. 4004 Small LENDER Act S. 4356 Lummis-Gillibrand Responsible Financial Innovation Act Bank Merger Policy Bank Secrecy Act/Anti-Money Laundering Rules/Legislation, including Beneficial Ownership Issue Banking Services Fees Cannabis Banking Central Bank Digital Currency Climate Risk Disclosure Requirements Climate-Related Financial Regulation Community Bank Access to Capital Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Consumer Financial Protection Bureau, report of financial services in rural America Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Cybersecurity Requirements Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Supplemental Capital Cryptocurrency Customer Data Access, Implementation of Dodd Frank Act Section 1033 Cybersecurity Data Security, Breaches and Privacy De Novo Bank Formation Dodd Frank Act 1071- Small Business Loan Data Collection Digital Assets Regulation Durbin Amendment on Interchange; Extension to Credit Cards Emergency Capital Investment Program Expanding Opportunity for Minority Depository Institutions Act (draft) Faster/Instant Payments FDIC Premium Increases FDIC Supervisory Appeals Review Committee and Policy Federal Reserve Accounts for Consumers Financial Data Privacy Discussion Draft Financial Inclusion 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 IRS Reporting of Financial Account Inflows/Outflows Minority Depository Institutions Issues OCC Proposed Payments Charter Overdraft Fees Overdraft Protection Patent Reform Legislation Postal Banking Protecting Consumers from Payment Scams Act (draft) SAFE Banking Act, support for inclusion in America COMPETES Act Conference SBA 7(a) Loan Program Funding and Terms SBA Direct 7(a) Direct Lending Secure Notarization Small Business Loan Data Collection--CFPB Implementation of Dodd-Frank Act Section 1071 Stablecoins Stablecoin Innovation and Protection Act of 2022 (draft) Stablecoin TRUST Act (draft) H.R. 4590 - Promoting New and Diverse Depository Institutions Act H. R. 5376 - Inflation Reduction Act of 2022 (Build Back Better) H.R. 6889 - The Credit Union Board Modernization Act H.R. 8443, Making the CFPB Accountable Act H.R. 8833, the Making Communities Stronger Through the Community Reinvestment Act H.R. 8874, Credit Card Competition Act H.R. 8950, the Digital Commodities Consumer Protection Act of 2022 S. 4522 - Transparency in CFPB Cost-Benefit Analysis Act S. 4674, Credit Card Competition Act S. 4831 No CBDC Act Amendments 69 and 70 to FY2023 FSGG Appropriations Bill (Postal banking) BankOn accounts Community Banks on Military Bases FDIC Deposit Insurance Assessments National Defense Authorization Act, opposition to inclusion of Credit Card Competition Act as an Amendment National Defense Authorization Act, report language on financial institution leases on military bases P2P Payment Applications Fraud Stablecoin Legislation - Waters-McHenry Discussion Draft Unfair, deceptive, or abusive acts and practices (UDAAP)
Client expense: $718,825 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
2022 · third_quarter · Banking
H.R. 1319, American Rescue Plan Act; H.R. 1417 - regarding credit union member business lending. Pay Check Protection Program implementation; credit union field of membership issues including maturity limits for federal credit unions; Fair lending; cannanis banking; Prompt Corrective Action for credit unions and capital reform. Community Development Finanical Institutions. Nominations for the CFPB's Credit Union Advisory Council. Expanding Finanical Access to Underserved Communities Act. Central Liquidity Enhancement Act. H.R. 3958, H.R. 2311, S.1767, H.R. 5189, S.762. H.R.7003 The Expanding Financial Acess for Underserved Communities Act, H.R. 6889 and S. 4325, The Credit Union Board Modernization Act. H.R. 2543.
Client expense: $110,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), SENATE, Treasury, Dept of
2022 · second_quarter · Economics/Economic Development
Extending and modifying the CDFI Bond Guarantee Program. Worked to advance the CDFI Bond Guarantee Program Improvement Act of 2022 (S.3441 and H.R.7733). Also worked on CDFI Bond Guarantee provisions included in the Financial Services Racial Equity, Inclusion, and Economic Justice Act (H.R.2543) as passed by the House on June 15, 2022.
Client expense: Not reported · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2022 · second_quarter · Financial Institutions/Investments/Securities
HR 2543 "Financial Services Racial Equity, Inclusion, and Economic Justice Act," all provisions.
Client expense: $110,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES
2022 · second_quarter · Banking
Closing the "rent-a-bank" loophole to bypass state regulations on usury caps Increased supervision and enforcement of BNPL and EWA Eliminating excessive banking fees, including overdraft Lender robosigning on collections for consumer credit CFPB rules of practice for adjudication proceedings Review merger of TD Bank Principles for responsible consumer and small business loans to prevent predatory lending Review and regulation of "junk fees" CFPB Examination of Nonbank mortgage, private loan, and payday loan entities Applicability of CFPB 1071 Rule to Farm Credit System Mandatory arbitration by credit monitoring agencies on reportable FCRA/FCBA complaints Urge CFPB reexamination of current late fee safe harbor amounts on credit cards H.R.5912 - Close the ILC Loophole Act, a bill to reform the regulation of industrial loan companies and their parent companies H.R.5974 / S.2508 - Veterans and Consumers Fair Credit Act, a bill to amend the Truth in Lending Act to extend the consumer credit protections provided to members of the Armed Forces and their dependents under title 10, United States Code, to all consumers S. 2677 - Stop Overdraft Profiteering Act, a bill to prohibit depository institutions from engaging in certain acts in connection with overdraft coverage S. 345 / H.R. 4277 - Overdraft Protection Act, a bill to prohibit a financial institution from engaging in unfair or deceptive acts in connection with overdraft coverage H.R. 2543 - FFederal Reserve Racial and Economic Equity Act, a bill to address access to financial services, diversity in various financial institutions and establishments, and other related issues H.R.6889 - Credit Union Board Modernization Act, a bill to amend the Federal Credit Union Act to modify the frequency of board of directors meetings, and for other purposes Nomination of Michael Barr to the Federal Reserve Board of Governors Namination of Lael Brainard to Federal Reserve Board of Governors Nomination of Lisa Cook to the Federal Reserve Board of Governors Nomination of Todd Harper to the National Credit Union Administration
Client expense: $80,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of
2022 · second_quarter · Financial Institutions/Investments/Securities
Issues pertaining to alternative data in mortgage underwriting, negative information on credit reports, medical debt, and credit checks for employment. H.R. 2543, Federal Reserve Racial and Economic Equity Act, issues pertaining to alternative data in mortgage underwriting, negative information on credit reports, medical debt, and credit checks for employment.
Client expense: $490,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES
2022 · second_quarter · Housing
H.R. 2483/S. 3237, Build More Housing Near Transit Act of 2021; H.R. 2126/S. 902, Housing Supply and Affordability Act; H.R. 3198/S. 1614, Yes in my Backyard Act; H.R. 6307, Tiny Homes for Homeless Veterans; Housing, Opportunity, Mobility, and Equity (HOME) Act; Build Back Better; S. 768, Better Planning and Land-Use for Accessible Neighborhoods Act; H.R. 1615, Maximizing Our Redevelopment and Efficiency for Transit Oriented Development (More TOD) Act of 2021; Task Force on the Impact of the Affordable Housing Credit Improvement Act; H.R. 2573/S. 1136, Affordable Housing Credit Improvement Act of 2021; H.R. 2143/S. 98, Neighborhood Homes Investment Act; H.R. 3680, Promoting Affordable Housing Near Transit Act; H.R. 816, Restoring Communities Left Behind Act; H.R. 1483, Revitalizing Economies, Housing, And Businesses (REHAB) Act of 2021; H.R. 1360, American Dream Down Payment Act of 2021; S. 1820, Choice in Affordable Housing Act of 2021; H.R. 1728, Strategy and Investment in Rural Housing Preservation Act of 2021; S. 2256, Charitable Conservation Easement Program Integrity Act of 2021; Housing tax credits; Community Development Block Grant program; Surface Transportation Black Grant program; Accessory Dwelling Units; Appointing Solomon Greene to the Office of Policy Development and Research at the Department of Housing and Urban Development; H.R. 2543, Federal Reserve Racial and Economic Equity Act; H.R. 4759/S. 2511, Revitalizing Downtowns Act.
Client expense: $140,000 · Firm income: Not reported
Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, SENATE
2022 · second_quarter · Financial Institutions/Investments/Securities
General issues related to consumer lending. H.R. 5974/S. 2508, the Veterans and Consumers Fair Credit Act. H.R. 4395, the Payment Choice Act. H.R. 2543, Federal Reserve Racial and Economic Equality Act. H.R. 5912 - Close the ILC Loophole Act.
Client expense: Not reported · Firm income: $60,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2022 · second_quarter · Banking
Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Durbin Interchange Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2561, Promoting Access to Capital in Unbanked Communities Act of 2021 S. 910, SAFE Banking Act 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." H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate LIBOR Act H.R. 5189, Member Business Loan Expansion Act S. 2508, Veterans and Consumer Fair Credit Act Perlmutter Amendment (H.Amdt.97) to H.R. 4350, National Defense Authorization Act of 2022 H.R. 2989, Financial Transparency Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act Coin Circulation S. 3779, Adjustable Interest Rate LIBOR Act H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking. H.R. 2543, Federal Reserve Racial and Economic Equity Act UDAAP Supervisory Policies and Adjudication Procedures Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Durbin Interchange Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2561, Promoting Access to Capital in Unbanked Communities Act of 2021 S. 910, SAFE Banking Act 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." H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate LIBOR Act H.R. 5189, Member Business Loan Expansion Act S. 2508, Veterans and Consumer Fair Credit Act Perlmutter Amendment (H.Amdt.97) to H.R. 4350, National Defense Authorization Act of 2022 H.R. 2989, Financial Transparency Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act Coin Circulation S. 3779, Adjustable Interest Rate LIBOR Act H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking. H.R. 2543, Federal Reserve Racial and Economic Equity Act UDAAP Supervisory Policies and Adjudication Procedures
Client expense: $1,740,000 · Firm income: Not reported
Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2022 · second_quarter · Financial Institutions/Investments/Securities
Lobbied House offices against H.R. 2543 - Federal Reserve Racial and Economic Equity Act
Client expense: $13,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES
2022 · second_quarter · Financial Institutions/Investments/Securities
H.R. 935, Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2021 H.R. 1087, Shareholder Political Transparency Act of 2021 H.R. 1187, Corporate Governance Improvement and Investor Protection Act H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 1602, Eliminate Barriers to Innovation Act of 2021 H.R. 2025/S. 840, To amend title 28, United States Code, to increase transparency and oversight of third-party litigation funding in certain actions, and for other purposes H.R. 2516, Promoting Diversity and Inclusion in Banking Act of 2021 H.R. 2543, Federal Reserve Racial and Economic Equity Act H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2570, Climate Risk Disclosure Act of 2021 H.R. 2620, Investor Choice Act of 2021 H.R. 3007, Disclosure of Tax Havens and Offshoring Act H.R. 3448, Helping Startups Continue to Grow Act H.R. 3454, Modernizing Disclosures for Investors Act H.R. 4277, Overdraft Protection Act of 2021 H.R. 4345, Financial Services and General Government Appropriations Act, 2022 H.R. 4350, National Defense Authorization Act for Fiscal Year 2022 H.R. 4521, America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength (America COMPETES) Act of 2022, including provisions related to House Amendment 218 H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate (LIBOR) Act of 2021 H.R. 4773, Consumer Financial Protection Commission Act H.R. 5586/S. 3056, Prohibiting IRS Financial Surveillance Act H.R. 5648/S. 3022, Stop Wall Street Looting Act H.R. 5910, Holding SPACs Accountable Act of 2021 H.R. 5911, Fair Hiring in Banking Act H.R. 7977, Promoting Opportunities for Non-Traditional Capital Formation Act S. 479, Lifting Our Communities through Advance Liquidity for (LOCAL) Infrastructure Act S. 2417, Credit Access and Inclusion Act of 2021 S. 2508, Veterans and Consumers Fair Credit Act S. 2621, Modernization of Derivatives Tax Act of 2021 S. 3410, The Consumer Protection and Due Process Act S. 3844, Economic Continuity and Stability Act S. 3914, Developing and Empowering our Aspiring Leaders Act of 2022 S. 4241, INvestor Democracy is EXpected (INDEX) Act Draft legislation titled Jumpstart our Business Startups (JOBS) Act 4.0 of 2022 Draft legislation titled Making appropriations for Financial Services and General Government for the fiscal year ending September 30, 2023, and for other purposes Potential legislation to foster economic growth and job creation through capital formation Potential legislation to further economic growth through environmental, social, and governance factors Potential legislation to speed up the timeline of the Holding Foreign Companies Accountable Act Potential legislation to enshrine SEC threshold ownership requirements for shareholder proposals Potential legislation to require the SEC to study barriers in accessing capital for minority entrepreneurs Potential legislation to expressing a sense of Congress reaffirming the Supreme Court materiality standard Potential legislation to require the SEC to consider additional standards in the rulemaking process Nomination of Mark Uyeda to be Commissioner of the U.S. Securities and Exchange Commission (SEC) Proposed rule regarding SEC Enhanced Reporting of Proxy Votes by Registered Management Investment Companies; Reporting of Executive Compensation Votes by Institutional Investment Managers Proposed Rule (86 Fed. Reg. 57,478-57,524, October 15, 2021) Proposed rule regarding SEC Reporting of Securities Loans (86 Fed. Reg. 69,802-69,853, December 8, 2021) Proposed rule regarding Position Reporting of Large Security-Based Swap Positions (87 Fed. Reg. 6,652-6,706, December 15, 2021) SEC Money Market Fund Reforms (86 Fed. Reg. 7,248, December 15, 2021) Proposed rules regarding amendments to Form PF (87 Fed. Reg. 9,106-9,235, January 26, 2022) Request for Information Regarding Fees Imposed by Providers of Consumer Financial Products or Services, Consumer Financial Protection Bureau; (87 Fed. Reg. 5,801-5,803, February 2, 2022) Request for Comment, Board of Governors of the Federal Reserve System; Framework for the Supervision of Insurance Organizations (87 Fed. Reg. 6,537-6,549, February 4, 2022) Procedural Rule, Request for Comment, Consumer Financial Protection Bureau; Supervisory Authority Over Certain Nonbank Covered Persons Based on Risk Determination; Public Release of Decisions and Orders (87 Fed. Reg. 25397-25398, April 29, 2022) Proposed Rule, Consumer Financial Protection Bureau; Prohibition on Inclusion of Adverse Information in Consumer Reporting in Cases of Human Trafficking (Regulation V) (87 Fed. Reg. 20,771-20,781, April 8, 2022) Proposed Rule, Federal Deposit Insurance Corporation; Rules, Regulations, Guidance, and Statement of Policy on Bank Merger Transactions (87 Fed. Reg. 18,740-18,744, March 31, 2022) Proposed Rule; Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure (87 Fed. Reg. 16,590-16,624, May 9, 2022) Proposed Rule, Securities and Exchange Commission; Private Fund Advisers; Documentation of Registered Investment Adviser Compliance Reviews (87 Fed. Reg. 16,886-16,977, March 24, 2022) Request for Comment, Federal Deposit Insurance Corporation; Statement of Principles for Climate-Related Financial Risk Management for Large Financial Institutions (87 Fed. Reg. 19,507-19,512, April 4, 2022) Various issues relating to SEC Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; Public Company Accounting Oversight Board (PCAOB); CFTCs de minimis Exception for Swap Dealers; Securities and Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); qualified mortgage definition under the Truth in Lending Act (P.L. 90-321) (Regulation Z); Financial Stability Oversight Council and the designation of Nonbank Financial Firms as systemically important; Federal Reserve Systems Large Institution Supervision Coordinating Committee; potential housing finance reform legislation; enforcement of Securities and Exchange Commission penalties; potential repeal of the State and Local Tax (SALT) Cap; federal interest rate authority; Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) reform; electronic consent-based SSN Verification Service (eCBSV); environmental, social, and governance (ESG) enforcement; information Collection under the Community Reinvestment Act (CRA) (P.L. 95-128); potential Financial Transaction Tax (FTT); potential Treasury Department proposal relating to tax reporting by banks; investment company cross trading; potential money market fund reform measures; resolutions to establish task forces on Artificial Intelligence and Financial Technology in the House Committee on Financial Services; transition to the secured overnight financing rate; implementation of SEC Rule 15c2-11; Department of Labor fiduciary advice exemption: PTE 2020-02; benefits of risk-based pricing; mobile disclosures; Federal Trade Commission issues: Freedom of Information Act Requests, Penalty Offense Authority, Zombie Voting, and overall direction of the Commission under Chair Lina Khan; Tax Reporting Proposal by the Department of the Treasury related to a $600 or more annual account threshold; Amendment to the FY22 National Defense Authorization Act related to credit reporting; Climate-Related Financial Risk Management for Large Banks; House Committee on Financial Services request for information related to Russia sanctions; Proposed Rule, Securities and Exchange Commission; Prohibition Against Fraud, Manipulation, or Deception in Connection with Security-Based Swaps, Prohibition against Undue Influence over Chief Compliance Officers, Position Reporting of Large Security-Based Swap Positions; Consumer Financial Protection Bureau (CFPB) activities, including a regulatory sandbox for disclosures; CFPB Policy Fellowship program; CFPB amendment of its Supervision and Examination Manual; CFPB conflation of Distinct Statutory Concepts of Unfairness and Discrimination Promoting the importance of appropriate length of SEC Comment Periods; EU sustainable finance action plan and incorporating ESG factors into financial services; EU review of Alternative Investment Fund Managers Directive; EU review of prudential regime for investment firms; implementation and enforcement of Regulation Best Interest by the Securities and Exchange Commission; changes in the enforcement policies of the Securities and Exchange Commission; activity of the Financial Stability Oversight Council and recommendations on macro-prudential regulation; clarification in the regulatory treatment of digital assets by the Securities and Exchange Commission and the Commodity Futures Trading Commission; implementation and enforcement of proxy advisory firm regulations finalized in 2020; implementation and enforcement of SEC 14a-8 shareholder proposal process reforms finalized in 2020; EU Money Market Fund Regulation, legislative review; electronic delivery of certain investment documents and disclosures; implementation of beneficial ownership reporting requirements under the National Defense Authorization Act FY2021 (P.L. 116-283); implementation of the Social Security Administrations Electronic Consent Based Social Security Number Verification System Service; Financial Stability Board recommendations on money market fund reform; IOSCO recommendations on sustainability-related practices, polices, procedures, and disclosure in asset management; Office of Financial Research (OFR) discussions on FSOC Report on Climate-Related Financial Risk; staff legal guidance at the SEC concerning no-action letters on shareholder proposals with broad societal impact (Staff Legal Bulletin 14L-CF); SEC reforms to regulations related to climate disclosures; SEC reforms to regulations related to Shareholder Proposals; SEC reforms to regulations related to Cybersecurity Disclosures; SEC reforms to regulations related to Human Capital Management Disclosures; SEC reforms to regulations related to Share Repurchase Disclosures; SEC reforms to regulations related to 10b5-1 Disclosure; SEC request for information on digital engagement practices; FinCEN Implementation of the Beneficial Ownership Requirements of the Corporate Transparency Act (P.L. 116-283); SEC Reopening of Comment Period on Pay Versus Performance; SEC Proposed Rule amending 10b5-1; SEC Amended Rule 15c2-11, applicability to 144A securities; SEC Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors; SEC prosed rule on private fund advisors; documentation of registered investment adviser compliance reviews; Proposed Rule, Securities and Exchange Commission; Share Repurchase Disclosure Modernization; Proposed Rule, Securities and Exchange Commission; The Enhancement and Standardization of Climate-Related Disclosures for Investors; Proposed Rule, Securities and Exchange Commission; Money Market Fund Reforms; Proposed Rule, Securities and Exchange Commission; Share Repurchase Disclosure Modernization; Notice, Internal Revenue Service; Priority Guidance Plan; Compliance Assistance Release, Department of Labor; 401(k) Plan Investments in Cryptocurrencies Request for Information, Consumer Financial Protection Bureau; Fees Imposed by Providers of Consumer Financial Products or Services; cybersecurity risk management and incident reporting; enhancement and standardization of climate related disclosures to investors SEC regulation
Client expense: $15,800,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
2022 · second_quarter · Financial Institutions/Investments/Securities
Legislative proposals impacting banking services for financial services providers; Payday, Vehicle Title, and Certain High-Cost Installment Loans; Federal policy relating to anticipated Consumer Financial Protection Bureau regulation of consumer financial services including payday and auto title lending, and regulatory process; FY2023 National Defense Authorization Act (H.R.7900); H.R.4395, Payment Choice Act of 2021; S.2349, Protecting Consumers from Unreasonable Credit Rates Act of 2021; S.2508/H.R.5974, Veterans and Consumers Fair Credit Act; H.R.2543, Federal Reserve Racial and Economic Equity Act.
Client expense: Not reported · Firm income: $60,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2022 · second_quarter · Civil Rights/Civil Liberties
H.R. 5129; Community Services Block Grant Modernization Act of 2022, Ensuring religious liberty H.R. 2543; Financial Services Racial Equity, Inclusion, and Economic Justice Act, Ensure the rights of women and female entrepreneurs H.R. 426; Protection of Women and Girls in Sports Act of 2021 (and its discharge petition), Ensuring the rights, safety, and opportunity of women and the preservation of Title IX H.R. 1620; Violence Against Women Act Reauthorization Act of 2021, Ensuring that battered women and religious liberty are protected
Client expense: $10,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2022 · second_quarter · Financial Institutions/Investments/Securities
HR 2543 "Financial Services Racial Equity, Inclusion, and Economic Justice Act," all provisions.
Client expense: $110,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES
2022 · second_quarter · Labor Issues/Antitrust/Workplace
H.R.4589 - Diversity and Inclusion at the Department of State Act and other policies that influence DEI within federal agencies. H.R. 2543, passed by the U.S. House of Representatives passed Financial Services Racial Equity, Inclusion and Economic Justice Act, a package of thirteen bills focused on promoting racial and economic justice throughout the financial services sector. The package included two bills authored by U.S. CONGRESSWOMAN AND CONGRESSIONAL BLACK CAUCUS CHAIR JOYCE BEATTY (OH-03): H.R. 2123, the Diversity and Inclusion Data Accountability and Transparency Act, and H.R.7953, the Expanding Opportunity for MDIs Act. An additional Beatty bill, the Ensuring Diverse Leadership Act, was adopted as an amendment to the bill before its passage.
Client expense: $70,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2022 · second_quarter · Banking
H.R. 1996 SAFE Banking Act H.R. 2543 Federal Reserve Racial and Economic Equity Act, Credit Union Provisions & Community Bank Amendment Amendment #6 to H.R. 2543, to repeal Section 1071 of the Dodd-Frank Act Sec. 521, 522, 523 & 524 of H.R.2543 - Federal Reserve Racial and Economic Equity Act H.R. 2561 Promoting Access to Capital in Underbanked Communities Act of 2021 H.R. 3009 Improving Language Access in Mortgage Servicing H.R. 4277 Overdraft Protection Act H.R. 4345 FY 2022 Financial Services and General Government Appropriation - Postal Banking Pilot Program H.R. 5376 The Build Back Better Act H.R. 5886 Prohibit IRS Financial Surveillance Act H.R. 5912 Close ILC Loophole Act H.R. 6037 Prohibit SBA 7(a) Direct Lending H.R. 6054 Small Business Lending Disclosure Act H.R. 6307 Protecting Access to Credit for Small Businesses Act H.R. 6732 Small LENDER Act H.R. 6739 Business Loan Privacy Act H.R. 6745 Ensuring Diversity in Community Banking Act H.R. 6802 Prevent Racial Profiling in Lending Act H.R. 6814 Small Business Fair Debt Collection Practices Act H.R. 7003 Expanding Financial Access for Underserved Communities Act H.R. 7022 Strengthening Cybersecurity Act H.R. 7412 Transparency in CFPB Cost-Benefit Analysis Act H.R. 7768 Farm Credit Administration Independence Authority Act H.R. 8152 American Data Privacy and Protection Act S. 910 SAFE Banking Act S. 1684 Federal Home Loan Banks Mission Implementation Act S. 3056 Prohibit IRS Financial Surveillance Act S. 3382 Protecting Access to Credit for Small Businesses Act S. 3409 A bill to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024, and for other purposes. S. 3441 CDFI Bond Guarantee Program Improvement Act S. 3715 E-Sign Modernization Act S. 3745 TAILOR Act S. 3954 Ban CBDC S. 4004 Small LENDER Act S. 4356 Lummis-Gillibrand Responsible Financial Innovation Act Bank Merger Policy Bank Secrecy Act/Anti-Money Laundering Rules/Legislation, including Beneficial Ownership Issue Banking Services Fees Cannabis Banking Central Bank Digital Currency Climate Risk Disclosure Requirements Climate-Related Financial Regulation Community Bank Access to Capital Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Consumer Financial Protection Bureau, report of financial services in rural America Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Cybersecurity Requirements Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Supplemental Capital Cryptocurrency Customer Data Access, Implementation of Dodd Frank Act Section 1033 Cybersecurity Data Security, Breaches and Privacy De Novo Bank Formation Dodd Frank Act 1071- Small Business Loan Data Collection Digital Assets Regulation Durbin Amendment on Interchange; Extension to Credit Cards Emergency Capital Investment Program Expanding Opportunity for Minority Depository Institutions Act (draft) Faster/Instant Payments FDIC Premium Increases FDIC Supervisory Appeals Review Committee and Policy Federal Reserve Accounts for Consumers Financial Data Privacy Discussion Draft Financial Inclusion 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 IRS Reporting of Financial Account Inflows/Outflows Minority Depository Institutions Issues OCC Proposed Payments Charter Overdraft Fees Overdraft Protection Patent Reform Legislation Postal Banking Protecting Consumers from Payment Scams Act (draft) SAFE Banking Act, support for inclusion in America COMPETES Act Conference SBA 7(a) Loan Program Funding and Terms SBA Direct 7(a) Direct Lending Secure Notarization Small Business Loan Data Collection--CFPB Implementation of Dodd-Frank Act Section 1071 Stablecoins Stablecoin Innovation and Protection Act of 2022 (draft) Stablecoin TRUST Act (draft)
Client expense: $1,840,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
2022 · second_quarter · Small Business
The NEW START Act of 2021 (HR 6326) Department of Treasury regulations on State Small Business Credit Initiative Hard-Hit Small Business Relief Fund (S 4471) Financial Services Racial Equity Inclusion and Economic Justice Act (HR 2543) Community Advantage loan program at SBA
Client expense: Not reported · Firm income: $30,000
Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, SENATE, Small Business Administration (SBA), Treasury, Dept of
2022 · second_quarter · Banking
The Financial Services Racial Equity Inclusion and Economic Justice Act (HR 2543) Community Reinvestment Act
Client expense: Not reported · Firm income: $30,000
Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2022 · second_quarter · Small Business
CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. SBA Direct Lending (Congress) Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements fall disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House) Legislation and Regulation - H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) H.R. 7768 - Farm Credit Administration Independence Authority Act (all sections) which is legislation to exempt the Farm Credit System from being regulated by the CFPB and from compliance with Section 1071 of the Dodd-Frank Act - small business data collection (House) H.R. 2543 - Federal Reserve Racial and Economic Equity Act - Amendment to include H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Letters - None Action Alerts - Action Alert regarding: Expanded Credit Union Powers / H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Miscellaneous - None
Client expense: $60,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES
2022 · second_quarter · Financial Institutions/Investments/Securities
CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve, and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Leadership for Bank Regulatory Agencies (Administration, Congress, and the Agencies) Recent nominees have held extreme views on the banking system and financial services and their nominations have increasingly caused unproductive political wrangling. Nominees should be qualified, hold reasonable positions, be willing to work collegially and cooperatively with colleagues and counterparts, serve the best interests of the banking and financial system and economy, and clearly understand the vital importance of and support community banks. Fintechs and Innovation in Financial Services (Congress and the Agencies) Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Special Purpose National Banks (SPNBs) (OCC) SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. SBA Direct Lending (Congress) Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Financial Inclusion (Congress and the Agencies) CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking (Congress) Public banking (i.e., publicly-owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) (FASB and the Agencies) Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements fall disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB) CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include including returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Bank Merger Activity (Congress and the Agencies) New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and FDIC) Legislation and Regulation - H.R. 5912 - Close the ILC Loophole Act (all sections) which is legislation to reform the regulation of industrial loan companies (ILCs) and their parent companies to provide for consolidated federal supervision (House) H.R. 4421 - America COMPETES Act of 2022 (in conference committee/reconciliation) H.R. 1996 - The SAFE Banking Act which permits the banking of cannabis related businesses in states where it is legal (House and Senate) H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) H.R. 7768 - Farm Credit Administration Independence Authority Act (all sections) which is legislation to exempt the Farm Credit System from being regulated by the CFPB and from compliance with Section 1071 of the Dodd-Frank Act - small business data collection (House) H.R. 2543 - Federal Reserve Racial and Economic Equity Act - Amendment to include H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Letters - Comment Letter to the Federal Reserve System regarding: Supplemental Notice and request for Comments, Guidelines for Evaluating Account and Service Requests - Docket No. OP-1747 (Federal Reserve) Comment Letter to the FDIC regarding: Statement of Principles for Climate-Related Financial Risk Management for Large Financial Institutions - RIN 3064-ZA32 (FDIC) Comment Letter to the Federal Reserve regarding: Money and Payments: The Digital Dollar in the Age of Digital Transformation (Federal Reserve) Comment Letter to the FDIC regarding: Guidelines for Appeals of Material Supervisory Determinations - RIN 3064-ZA20 (FDIC) Action Alerts - Action Alert regarding: Expanded Credit Union Powers / H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Miscellaneous - Comment Letter to the CFPB about Fees Imposed by Providers of Financial Products or Services (FDIC and House) Application to CFPBs regulatory sandbox (CFPB) Comment Letter to the Federal Reserve about Money and Payments: The Digital Dollar in the Age of Digital Transformation (House)
Client expense: $60,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE
2022 · second_quarter · Taxation/Internal Revenue Code
CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Community Bank Positions on New and Emerging Issues - Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House) Legislation and Regulation - H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) H.R. 2543 - Federal Reserve Racial and Economic Equity Act - Amendment to include H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Letters - None Action Alerts - Action Alert regarding: Expanded Credit Union Powers / H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Miscellaneous - None
Client expense: $60,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES
2022 · second_quarter · Consumer Issues/Safety/Products
CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve, and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. Financial Inclusion (Congress and the Agencies) CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Postal Banking (Congress) Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking (Congress) Public banking (i.e., publicly-owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB) CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include including returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House) Legislation and Regulations - H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) H.R. 2543 - Federal Reserve Racial and Economic Equity Act - Amendment to include H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Letters - Comment Letter to the Federal Reserve - Money and Payments: The Digital Dollar in the Age of Digital Transformation (Federal Reserve) Action Alerts - Action Alert regarding: Expanded Credit Union Powers / H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Miscellaneous - Comment Letter to the CFPB about Fees Imposed by Providers of Financial Products or Services (FDIC and House) Application to CFPBs regulatory sandbox (CFPB) Comment Letter to the Federal Reserve about Money and Payments: The Digital Dollar in the Age of Digital Transformation (House)
Client expense: $60,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES
2022 · second_quarter · Banking
CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve, and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Leadership for Bank Regulatory Agencies (Administration, Congress, and the Agencies) Recent nominees have held extreme views on the banking system and financial services and their nominations have increasingly caused unproductive political wrangling. Nominees should be qualified, hold reasonable positions, be willing to work collegially and cooperatively with colleagues and counterparts, serve the best interests of the banking and financial system and economy, and clearly understand the vital importance of and support community banks. Fintechs and Innovation in Financial Services (Congress and the Agencies) Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Special Purpose National Banks (SPNBs) (OCC) SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. SBA Direct Lending (Congress) Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Financial Inclusion (Congress and the Agencies) CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking (Congress) Public banking (i.e., publicly-owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) (FASB and the Agencies) Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements fall disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB) CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include including returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Bank Merger Activity (Congress and the Agencies) New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and FDIC) Legislation and Regulation - H.R. 5912 - Close the ILC Loophole Act (all sections) which is legislation to reform the regulation of industrial loan companies (ILCs) and their parent companies to provide for consolidated federal supervision (House) H.R. 4421 - America COMPETES Act of 2022 (in conference committee/reconciliation) H.R. 1996 - The SAFE Banking Act which permits the banking of cannabis related businesses in states where it is legal (House and Senate) H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) H.R. 7768 - Farm Credit Administration Independence Authority Act (all sections) which is legislation to exempt the Farm Credit System from being regulated by the CFPB and from compliance with Section 1071 of the Dodd-Frank Act - small business data collection (House) H.R. 2543 - Federal Reserve Racial and Economic Equity Act - Amendment to include H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Letters - Comment Letter to the Federal Reserve System regarding: Supplemental Notice and request for Comments, Guidelines for Evaluating Account and Service Requests - Docket No. OP-1747 (Federal Reserve) Comment Letter to the FDIC regarding: Statement of Principles for Climate-Related Financial Risk Management for Large Financial Institutions - RIN 3064-ZA32 (FDIC) Comment Letter to the Federal Reserve regarding: Money and Payments: The Digital Dollar in the Age of Digital Transformation (Federal Reserve) Comment Letter to the FDIC regarding: Guidelines for Appeals of Material Supervisory Determinations - RIN 3064-ZA20 (FDIC) Action Alerts - Action Alert regarding: Expanded Credit Union Powers / H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Miscellaneous - Comment Letter to the CFPB about Fees Imposed by Providers of Financial Products or Services (FDIC and House) Application to CFPBs regulatory sandbox (CFPB) Comment Letter to the Federal Reserve about Money and Payments: The Digital Dollar in the Age of Digital Transformation (House)
Client expense: $60,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE
2022 · second_quarter · Banking
H.R. 1319, American Rescue Plan Act; H.R. 1417 - regarding credit union member business lending. Pay Check Protection Program implementation; credit union field of membership issues including maturity limits for federal credit unions; Fair lending; cannanis banking; Prompt Corrective Action for credit unions and capital reform. Community Development Finanical Institutions. Nominations for the CFPB's Credit Union Advisory Council. Expanding Finanical Access to Underserved Communities Act. Central Liquidity Enhancement Act. H.R. 3958, H.R. 2311, S.1767, H.R. 5189, S.762. H.R.7003 The Expanding Financial Acess for Underserved Communities Act, H.R. 6889 and S. 4325, The Credit Union Board Modernization Act. H.R. 2543
Client expense: $110,000 · Firm income: Not reported
Government targets: Consumer Financial Protection Bureau (CFPB), HOUSE OF REPRESENTATIVES, Natl Credit Union Administration (NCUA), SENATE, Treasury, Dept of
2022 · second_quarter · Housing
1.Nomination of Julia Gordon for FHA Commissioner 2.Nomination of Sandra Thompson for FHFA Director 3.FHFA OIG report on supervision 4.GSE Equity Plans 5.HR 7022, Strengthening Cybersecurity for the Financial Sector Act of 2022 6.P.L. 116-136, CARES Act - implementation issues related to mortgage forbearance and servicer liquidity 7.Issues related to mortgage servicer implementation of borrower forbearance and other borrower assistance under the CARES Act and The American Rescue Plan (Homeowner Assistance Fund). 8.Issues related to appraisal regulation and down payment assistance 9.HR 5376, Build Back Better Act 10.S. 2428 - False Claims Amendments Act of 2021 11.S 2429 - Administrative False Claims Act of 2021 12.HR 2543, Federal Reserve Racial & Economic Equity Act 13.HR 7049, Mortgage Borrower Protection Act of 2022 14.S 1625, HR 3962 Securing and Enabling Commerce Using Remote and Electronic Notarization Act of 2021 15.HR 2553, Real Estate Valuation Fairness and Improvement Act of 2021 16.HR 4495, Downpayment Toward Equity Act of 2021
Client expense: $150,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2022 · second_quarter · Financial Institutions/Investments/Securities
1.Nomination of Julia Gordon for FHA Commissioner 2.Nomination of Sandra Thompson for FHFA Director 3.FHFA OIG report on supervision 4.GSE Equity Plans 5.HR 7022, Strengthening Cybersecurity for the Financial Sector Act of 2022 6.P.L. 116-136, CARES Act - implementation issues related to mortgage forbearance and servicer liquidity 7.Issues related to mortgage servicer implementation of borrower forbearance and other borrower assistance under the CARES Act and The American Rescue Plan (Homeowner Assistance Fund). 8.Issues related to appraisal regulation and down payment assistance 9.HR 5376, Build Back Better Act 10.S. 2428 - False Claims Amendments Act of 2021 11.S 2429 - Administrative False Claims Act of 2021 12.HR 2543, Federal Reserve Racial & Economic Equity Act 13.HR 7049, Mortgage Borrower Protection Act of 2022 14.S 1625, HR 3962 Securing and Enabling Commerce Using Remote and Electronic Notarization Act of 2021 15.HR 2553, Real Estate Valuation Fairness and Improvement Act of 2021 16.HR 4495, Downpayment Toward Equity Act of 2021
Client expense: $150,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE