Central Liquidity Facility Enhancement Act

Protect the credit union tax exemption; Oppose S. 4698, the Improving Cybersecurity of Credit Unions Act- Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; support S. 4165; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; 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; extend GLBA like data security measures to retailers; recognized GLBA compliance in any privacy legislation; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for S.4879/H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412/S.4522, the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; oppose NCUA proposed rule on Succession Planning (RIN: 3133-AF42); general support for Re-Proposal to Enhance Eligibility Requirements for Enterprise Single-Family Seller/Servicers; need greater clarity regarding Guidelines for Evaluating Account and Services Requests (Docket No. Docket No. OP-1747); adopt more flexible rules for acceptance and delivery of electronic signatures and disclosures; support for CFPB commission rather than single director; support for H.R. 7628, the Improve the SBA Act; Asset Threshold for Determining the Appropriate Supervisory Office (RIN: 3133-AF41) - specialized oversight of larger credit unions should be calibrated to reflect relative risk to the SIF today and not defined using an outdated asset threshold; provide greater flexibility related to Permissible Interest Rate Ceiling; NCUA should practice restraint regarding budgeting and be more transparent; support for alternative credit scoring models; not sufficient evidence to justify development of CBDC; do not let the NFIP lapse; the NCUA should eliminate the internal written loan participation policy requirements found at 701.22(b)(5)(iv); HUD should allow the option of 40-year mortgage loans; support for HR6889/S. 4325, the Credit Union Board Modernization Act; improve Veterans access to capital by exempting credit unions' business loans to veterans from the MBL cap; expand 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; make permanent NCUAs authorities for the Central Liquidity Facility (CLF) granted under the CARES Act; support for H.R. 5912, the Close the ILC Loophole Act; support for H.R. 7733, the CDFI Bond Guarantee Program Improvement Act; support H.R. 3962, the SECURE Notarization Act; opposition to H.R. 4277, the Overdraft Protection Act; H.R. 6814, the Small Business Fair Debt Collection Protection Act - the FDCPA changes should not improperly burden creditors; opposed to the following 2 bills in their current form: H.R. 7022, the Strengthening Cybersecurity for the Financial Sector Act, and H.R. 8152, the American Data Privacy and Protection Act, Excluding bank lease provision from S. 4543, the FY 2023 NDAA; support for H.R. 5911, the Fair Hiring in Banking Act (as an amendment to H.R. 7900, the FY 2023 NDAA); support for H.R. 3958, the Central Liquidity Facility Enhancement Act; support for H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support for FY 2023 FSGG appropriations in H.R. 8294; oppose interchange legislation: S. 4674/H.R. 8874, the Credit Card Competition Act of 2022; opposed to H.R. 8485, the Expanding Access to Credit through Consumer-Permissioned Data Act; Comments to Department of Commerce related to RIN 0625-XC04; NCUA Regulations Part 701.36, Occupancy Rule; NCUA 2022 Mid-Session Budget; Comments to CFPB related to Docket No. CFPB-2022-0039; Petition to CFPB on rulemaking for larger participants in aggregation services market; Comments to FinCEN related to RIN No.: 1506- AB55; Comments to Treasury related to Request for Comment Document No. 2022-14588; Comments to NCUA related to 2022 Regulatory Review; Opposing expansion of Regulation E liability; Comments to FCC related to Docket No. FCC 21-105; Comments to CFPB related to Docket No. CFPB-2022-0040; Comments to Federal Reserve related to Docket No. R-1775; Deadline extension request for Docket No. CFPB-2022-0048; NCUA Simplified CECL Tool; Comments to NCUA related to RIN 3133-AF47; FHFA oversight - support incorporation of climate change into GSE/FHFA governance, Supporting appraisal modernization, and Supporting CDFI mortgage programs.

Client expense: $1,160,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), 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

Protect the credit union tax exemption; Oppose S. 4698, the Improving Cybersecurity of Credit Unions Act- Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; support S. 4165; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; 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; extend GLBA like data security measures to retailers; recognized GLBA compliance in any privacy legislation; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for S.4879/H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412/S.4522, the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; oppose NCUA proposed rule on Succession Planning (RIN: 3133-AF42); general support for Re-Proposal to Enhance Eligibility Requirements for Enterprise Single-Family Seller/Servicers; need greater clarity regarding Guidelines for Evaluating Account and Services Requests (Docket No. Docket No. OP-1747); adopt more flexible rules for acceptance and delivery of electronic signatures and disclosures; support for CFPB commission rather than single director; support for H.R. 7628, the Improve the SBA Act; Asset Threshold for Determining the Appropriate Supervisory Office (RIN: 3133-AF41) - specialized oversight of larger credit unions should be calibrated to reflect relative risk to the SIF today and not defined using an outdated asset threshold; provide greater flexibility related to Permissible Interest Rate Ceiling; NCUA should practice restraint regarding budgeting and be more transparent; support for alternative credit scoring models; not sufficient evidence to justify development of CBDC; do not let the NFIP lapse; the NCUA should eliminate the internal written loan participation policy requirements found at 701.22(b)(5)(iv); HUD should allow the option of 40-year mortgage loans; support for HR6889/S. 4325, the Credit Union Board Modernization Act; improve Veterans access to capital by exempting credit unions' business loans to veterans from the MBL cap; expand 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; make permanent NCUAs authorities for the Central Liquidity Facility (CLF) granted under the CARES Act; support for H.R. 5912, the Close the ILC Loophole Act; support for H.R. 7733, the CDFI Bond Guarantee Program Improvement Act; support H.R. 3962, the SECURE Notarization Act; opposition to H.R. 4277, the Overdraft Protection Act; H.R. 6814, the Small Business Fair Debt Collection Protection Act - the FDCPA changes should not improperly burden creditors; opposed to the following 2 bills in their current form: H.R. 7022, the Strengthening Cybersecurity for the Financial Sector Act, and H.R. 8152, the American Data Privacy and Protection Act, Excluding bank lease provision from S. 4543, the FY 2023 NDAA; support for H.R. 5911, the Fair Hiring in Banking Act (as an amendment to H.R. 7900, the FY 2023 NDAA); support for H.R. 3958, the Central Liquidity Facility Enhancement Act; support for H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support for FY 2023 FSGG appropriations in H.R. 8294; oppose interchange legislation: S. 4674/H.R. 8874, the Credit Card Competition Act of 2022; opposed to H.R. 8485, the Expanding Access to Credit through Consumer-Permissioned Data Act; Comments to Department of Commerce related to RIN 0625-XC04; NCUA Regulations Part 701.36, Occupancy Rule; NCUA 2022 Mid-Session Budget; Comments to CFPB related to Docket No. CFPB-2022-0039; Petition to CFPB on rulemaking for larger participants in aggregation services market; Comments to FinCEN related to RIN No.: 1506- AB55; Comments to Treasury related to Request for Comment Document No. 2022-14588; Comments to NCUA related to 2022 Regulatory Review; Opposing expansion of Regulation E liability; Comments to FCC related to Docket No. FCC 21-105; Comments to CFPB related to Docket No. CFPB-2022-0040; Comments to Federal Reserve related to Docket No. R-1775; Deadline extension request for Docket No. CFPB-2022-0048; NCUA Simplified CECL Tool; Comments to NCUA related to RIN 3133-AF47; FHFA oversight - support incorporation of climate change into GSE/FHFA governance, Supporting appraisal modernization, and Supporting CDFI mortgage programs.

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

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

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

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

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

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, The Credit Union Board Modernization Act.

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

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

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Governance Modernization for Credit Unions; support exam modernization for CUs; Supports Efforts to Promote De Novo Credit Union Formation; support transparent and responsible budget for NCUA; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to confirm that a credit union may directly, or in partnership with a CUSO or other third party vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; supported H.R. 5189, the Member Business Loan Expansion Act; Oppose New IRS Reporting Requirements for Financial Institutions; support comprehensive national data security standard covering all entities that collect and store consumer information - cost of data breach should be paid by responsible party - supports requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; urge NCUA to remove the aggregate loan participation cap altogether or make the temporary threshold permanent; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support the PPP Direct Borrower Forgiveness Process; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change; support H.R. 4773, the Consumer Financial Protection Commission Act; concerns with the recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs); request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; NCUA should consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests; request that the Board of Governors of the Fed withdraw the recent Federal Reserve proposal to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF - make changes to CLF permanent; support H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality; urge congress to exempt all credit unions from 36% Interest Rate Cap; support Raising CDFI funding and CDRLF funding; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; concerns with proposals to create an entirely new government-run consumer banking system, such as the FedAccounts; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; positive impacts of bank and credit union mergers; support non-regulatory approaches for encouraging the use and acceptance of AI technologies; credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation; FASB should exempt all non-public filers from compliance with CECL; lower the Complex Credit Union Leverage Ratio; oppose NCUAs Risk-Based Capital; 2022-2024 Enterprise Housing Goals (RIN: 2590-AB12); CFPB should utilize exemption authority under sec. 1022 of the Dodd Frank Act to exempt credit unions from certain rules and regulations; clarify UDAAP; adoption of E-sign; Subordinated Debt; RIN: 3133-AF38; Dept. of Treasurys Strategic Plan for Fiscal Years 2022-2026; regulate FinTechs and other nonbanks to even playing field; courtesy pay programs; buy now pay later; oppose H.R. 4277; support legislative process for legacy LIBOR contracts to be updated; regulation of consumer reporting agencies; Request for extension of the deadline to file comments to the proposed small business lending data collection under the Equal Credit Opportunity Act, Docket No. CFPB-2021-0015; RIN 3170- AA09; Request NCUA to Extend of Call Report Changes; PWG should clarify that credit unions have parity regarding stablecoins - parity in the digital asset space; support H.R. 5911, the Fair Hiring in Banking Act; support S. 1838, the Building Credit Access for Veterans Act of 2021; support H.R. 6037, Legislation Prohibiting Direct Lending; support S. 3382, the Protecting Access to Credit for Small Businesses Act; support H.R. 6038, the CFPB-IG Act of 2021; Enterprise Regulatory Capital Framework Rule (RIN: 2590-AB17); support the continued use of CRT to ensure stability in the housing finance system; allow GSEs to participate in pilot programs and purchase mortgages that are non-conforming to boost affordable and sustainable housing for low-income and underserved borrowers; hold big tech payment platforms accountable for complaint resolution processes; support FASBs proposal to eliminate accounting guidance for TDRs.

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

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. The Expanding Financial Acess for Underserved Communities Act, The Credit Union Board Modernization Act.

Client expense: $110,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Justice, Dept of (DOJ), Natl Credit Union Administration (NCUA), SENATE, Treasury, Dept of

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

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; oppose a premium charge on credit unions; support additional investment authorities for credit unions; Supports Allowing Credit Unions to Do More to Help Underserved Populations; Supports Governance Modernization for Credit Unions; Supports Efforts to Promote De Novo Credit Union Formation; request NCUA remove the requirement for NCUA guidance prior to invocation of the emergency exception to the in-person quorum requirement; supports expanding the ability of credit unions to add underserved areas to their field of membership; urge the Committee to consider and advance legislation to improve the chartering process for new credit unions as well as to consider ways to reduce the regulatory burden that discourages new credit union formation; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; support a moratorium on new ILC charters and closing the BHCA ILC loophole; supports H.R. 2311, the Credit Union Governance Modernization Act of 2021; supports the aim of the draft Expanding Opportunities in Banking Act in reducing barriers to employment; recommends the NCUA adopt a three-year phase-in of the stress testing requirement in Subpart E of Part 702 for Tier II covered credit unions; asks the NCUA to promptly issue a Letter to Credit Unions confirming that a credit union may directly, or in partnership with a credit union service organization (CUSO) or other thirdparty vendor, host a digital wallet capable of holding digital assets that are not securities; encourages the NCUA to adopt a form-agnostic approach to assessing credit unions adoption of digital assets and related technologies and to develop a digital asset adoption sandbox; opposition to provisions in the House Small Business Committee language from the Build Back Better Act that could allow the Small Business Administration (SBA) to directly offer a 7(a) loan product to market; supported legislation such as H.R. 5189, the Member Business Loan Expansion Act, which would make it easier for credit unions to offer smaller business loans under $100,000; Oppose New IRS Reporting Requirements for Financial Institutions in the Build Back Better Act; urges the NCUA to scrutinize its cash needs, provide greater transparency to credit unions on those needs, and return any surplus funds to credit unions directly or via a credit against 2022 budgeted expenses; urge Congress to amend certain portions of the Electronic Fund Transfer Act and direct the CFPB to issue updates to Regulation E to clarify that fintech providers should hold some responsibility for resolving errors; support comprehensive national data security standard covering all entities that collect and store consumer information; support Delegation of privacy enforcement authority to the appropriate sectoral regulator; : Opposition to New Tax Information Reporting Proposal; urge NCUA to remove the aggregate loan participation cap altogether, or in the alternative, make the temporary threshold permanent upon its expiration at the end of the year; supports the Boards desire to make FedNow interoperable with private sector networks to maximize the reach and accessibility of real time payments; comment on the proposed amendments and modifications to Regulation J pertaining to the release of FedNow; express concerns about Regulation E's risk allocation framework in the context of instant payments; requests that the Board provide financial institutions with the necessary tools to ensure that consumer initiated FedNow transactions can reach beneficiaries entirely through the FedNow network and allow these transactions to be treated exclusively as UCC 4A transactions; support Proposed Legislation to Allow Credit Unions to Better Serve Underserved Areas; support the PPP Direct Borrower Forgiveness Process for loans under $150,000; urge HUD to clarify the elements of a prima facia case to reflect Inclusive Communities; supports strong and effective fair lending rules for credit unions that are responsive to technological change.; support H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission; request a meeting to discuss our concerns regarding the most recent amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac (GSEs) and their impacts on the housing market; request that the Treasury and FHFA move quickly to amend the PSPAs to remove the product and program restrictions, including the cash window, to help communities in need get access to affordable mortgage credit; requests that the NCUA provide express guidance about its expectations or recommendations regarding whether corporate governance documents from merged credit unions would be appropriate for periodic destruction; encourages the NCUA to provide clear supervisory expectations for how credit unions must incorporate the national AML/countering the financing of terrorism (CFT) priorities; encourages NCUA to coordinate with the Financial Crimes Enforcement Network (FinCEN) in ensuring sensible regulation and exams are tailored to actual risks; asks that the NCUA finalize its Interagency Questions and Answers Regarding Flood Insurance with additional clarity to help credit unions comply with the flood insurance rule; U requests that the NCUA consider whether credit unions may benefit from additional flexibility when offering post-employment benefits; urges the NCUA to embrace transparency in its approach to Freedom of Information Act (FOIA) requests.; asks the NCUA to carefully evaluate how it plans to utilize remaining resources in 2021 and revisit its 2022 draft budget which included an 8.3 percent increase to the operating budget; request that the Board of Governors of the Federal Reserve System (Board) withdraw the recent Federal Reserve proposal (Proposal) to amend Regulation II; requests that the Board provide further analysis on the impacts of the proposed modification on the payment routing ecosystem; Support for Crapo Amendment to the Fiscal Year 2022 Budget Resolution; urges Ginnie Mae to provide credit unions parity with banks and exclude all credit unions from the additional capital requirements imposed on non-depository institutions proposed in this RFI; opposes any effort to extend debit interchange price caps or routing requirements to credit cards.; supports expanding the ability of credit unions to add underserved areas to their field of membership; supports S. 762, the Expanding Access to Lending Options Act,; supports S. 1767, the Credit Union Employee and Member Safety Act; support for H.R. 3958, the Central Liquidity Facility Enhancement Act, which would make the important changes to the CLF; support legislative efforts such as the bipartisan H.R. 4590, the Promoting New and Diverse Depository Institutions Act; supports amendments to the PSR policy that are designed to conform intraday credit and overnight overdraft policies with the 24x7x365 operating environment of FedNow; recommends that the Board decouple the LMT from FedNow participation so that all credit unions with accounts at Reserve Banks may benefit from its functionality.; urge congress to exempt all credit unions from 36% Interest Rate Cap to Everyone; support Raising CDFI funding from $270 to $330 million and CDRLF funding to $4 million; oppose expanding the capabilities of the USPS to provide additional banking services; suggestions for H.R. 4502; support bringing the NOL closer to the traditional level of 1.30 percent; express concerns with proposals before the Subcommittee today to create an entirely new government-run consumer banking system, such as the FedAccounts proposal and postal banking; asks that credit union expenditures for breaches resulting from card use be reduced.; supports the passage of legislation requiring any entity responsible for the storage of consumer data to meet standards similar to those imposed on depository institutions under the GLBA; support Enforcement of Prohibition on Data Retention; supports an approach that maintains the current NACHA rules; supports a fair and effective set of rules for incentivizing high quality origination practices; urge Amendments to the Member Business Lending (MBL) cap on federal credit unions; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation; supports efforts to promote a uniform and transparent framework for evaluating access requests for Reserve Bank services centered on a foundation of risk management and mitigation.; express concerns on Proposed Guidelines for Evaluating Account and Services Requests; defend against ICBA attacks; explain positive impacts of bank and credit union mergers; supported non-regulatory approaches for encouraging the use and acceptance of AI technologies; agrees with the Agencies that credit unions must adopt AI innovations safely and encourages the NCUA to approach fair lending risks through the framework of existing law and regulation.

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

Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions

Protect the credit union tax exemption; support regulators commitment to facilitate responsible experimentation with artificial intelligence and machine learning technology; recommended that the MRMG support use of AI and ML models and recognize the role of existing vendor due diligence for BSA/AML compliance; Supports Efforts to Reduce Barriers to Innovation; support the recommendation that agencies consider using any authority under existing law or regulation to grant waivers and exemptions from regulations, or to allow pilot programs that provide safe harbors for specific AI applications; support S. 2131, the Improving FHA Support for Small-Dollar Mortgages Act of 2021; reject efforts aimed at blanket suppression of adverse information in credit reports; express concern about the Protecting Your Credit Score Acts right of action; support the Protecting Your Credit Score Acts efforts to hold CRAs accountable for their obligations under GLBA and to improve data security at the CRAs; support for increased funding for the Community Development Financial Institutions (CDFI) Fund and the Community Development Revolving Loan Fund (CDRLF); express concern with allowing the USPS to provide banking services; request that the FHFA and Treasury urgently make the necessary adjustments to the PSPAs to allow credit unions to continue utilizing the GSE Patch until October 2022; encourage the NCUA Board to explore a floating interest rate ceiling that allows for adequate risk-based pricing models and mitigates interest rate risk; encourage the NCUA Board to consider increasing the interest rate ceiling upon its expiration or reaffirm the current 18 percent interest rate ceiling and avoid lowering the rate; support for S.J.Res.15, which would repeal the rule submitted by the Office of the Comptroller of the Currency (OCC) relating to National Banks and Federal Savings Associations as Lenders (the True Lender rule); express concerns about any increased reporting requirements on financial institutions, especially those in the Presidents 2022 budget request; supports H.R. 3958, the Central Liquidity Facility Enhancement Act, which makes the changes to the CLF in section 4016 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permanent; urges the NCUA to extend the IFRs automatic expiration to temporarily amend Part 702, Subpart B (Subpart B) of its prompt corrective action (PCA) regulations to December 31, 2022 to fully provide FICUs the financial planning and operational flexibilities necessary to meet compounding share growth; encourages the NCUA to carefully consider whether the streamlined NWRP model may be permanently adopted; urge FASB to conduct a roundtable with credit unions and other small financial institutions to discuss the impacts of the adoption of the current expected credit losses (CECL); express concerns about the appropriateness of CECL for credit unions; support inclusion of the SSBCI program as part of the overall American Rescue Plan Act of 2021 (ARPA) and express concerns about the wide latitude the statue affords to states in the development and execution of the program; encourage Treasury to provide additional guidance, FAQs, or training that can help CDFI and MDI credit unions prepare for and find opportunities within the SSBCI program; requests that the NCUA minimize examination burdens and understand the difficulties in obtaining independent validations of BSA and OFAC models employed at credit unions; urge agencies to consult the Federal Financial Institutions Examination Councils (FFIEC) examination reports and supervisory information through regular information sharing to better assess changes to the MRMG principles to reflect current practices; fully funding both the CDFI Fund and CDRLF at levels proposed in the Presidents FY2022 budget request, or at least above the FY2021 funding levels; support providing ample funding to support SBAs 7(a) and 504 loan programs; support legislation Expanding Financial Access for Underserved Communities Act, that would allow all types of credit unions to add underserved areas and make it easier to make critical member business loans to small businesses in those areas; urge you to implore the SBA to continue to streamline PPP loan forgiveness process; support H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID- 19 Crisis Act of 2021; support for MBL cap relief as a step to make it easier for credit unions to do more to help small businesses in light of the pandemic; support the use of alternative credit score models to enhance access to affordable credit for creditworthy borrowers who have historically been marginalized; support for the National Credit Union Administrations (NCUA) interim final rule extending statutory enhancements to the Central Liquidity Facility (CLF); support making the amendments in the CARES Act and their extension in the Consolidated Appropriations Act, 2021 permanent; encourage NCUA to provide broader relief regarding the timeframe for calculating credit union assets to assist those credit unions that have seen remarkable share growth during the pandemic; encourage NCUA to clarify its reservation of authority to subject certain credit unions to the enhanced regulatory requirements in Subpart E; request enhanced coordination with the Consumer Financial Protection Bureau (CFPB) regarding examinations generally and asset threshold measurement for purposes of supervision and examinations; urge NCUA to finalize all remaining COVID-19-related regulatory relief and to take additional steps to provide reform that will help credit unions better serve their communities; support rule permitting credit unions to capitalize interest under Appendix B to Part 741 as well as its proposed rule eliminating the prescribed 45-day limit in its requirements for an overdraft policy in NCUAs lending rule; urge three-year phase-in of the Current Expected Credit Loss (CECL) methodology and reconsider and simplify the NCUAs 2015 risk-based capital (RBC) rule; support modernizing the definition of service facility in its Chartering and Field of Membership Manual to allow credit unions to leverage digital banking platforms to serve broader segments of their communities; urge NCUA modernize its regulations related to compensation in connection with lending to permit comprehensive incentive plans; oppose granting additional authority to NCUA to examine third parties at this time, as NCUA should stay focused on where their expertise lies-regulating credit unions; oppose changes to the structure of the share insurance fund or a premium charge on credit unions; opposes any effort to extend debit interchange price caps or routing requirements to credit cards; Supports the Expanding Financial Access for Underserved Communities Act; support H.J.Res.35, which would repeal OCC True Lender rule; respond to and correct inaccuracies included in letter from the American Bankers Association (ABA) regarding the mergers of banks and credit unions; supports the development of an alternative to the agencys final RBC rule, such as a an off-ramp which aims to reduce the complexity of risk based capital compliance (i.e., the CCULR), or a risk based leverage ratio (RBLR) that is tailored to produce a less burdensome and less complex capital standard; support eliminating tiered risk weighting system and encourages the NCUA to streamline in the RBLR any assessment of concentration risk; support proposed rule adding an S component and redefining the L component of the existing CAMEL rating system, requests that the NCUA release more robust details about their expectations of credit unions meeting any new standards for the S component and what this change will mean for the examination process; express concern about exam inconsistency; urges the Bureau to provide clarity surrounding this rules early intervention requirements and the streamlined loan modification option; support exemptions to proposed pre-foreclosure review period; encourages amendments that provide additional loss mitigation options; FinCENs commitment to implementing the FinCEN Database to combat illicit activity in our U.S. financial system; urge FinCEN to consult with the NCUA and other federal banking regulators to ensure there are consistent examination and supervisory expectations for the use of beneficial ownership information; support the NCUAs proposed revision of its regulations to allow CUSOs to originate all loans that federal credit unions (FCUs) can originate, but requests that the NCUA solicit comment through the notice and rulemaking process before permitting additional CUSO activities; express concerns with the reemergence of rent-a-bank schemes, share our support for S.J.Res.15; urge creating a FFIEC subcommittee on emerging technology (the subcommittee) to monitor the risks posed by fintech companies; urge Congress to ensure that a fintech charter recipient is supervised as if it were a bank; supports the Committee reestablishing the Task Force on Artificial Intelligence and the Task Force on Financial Technology; generally support efforts to support DEI through legislation such as the Diversity and Inclusion Data Accountability and Transparency Act (H.R. 2123), the Promoting Diversity and Inclusion in Banking Act (H.R. 2516), and the Federal Reserve Racial and Economic Equity Act (H.R. 2543); supports the efforts in H.R. 2553 to require a review of federal appraisal standards; generally support H.R. 2547, the Comprehensive Debt Collection Improvement Act, but caution against hampering legitimate debt collection efforts; support H.R. 1996, the SAFE Banking Act of 2021; urge FHFA to adopt a risk-based framework for regulating and supervising the GSEs in the face of climate change; oppose FHFA implementing any policies and requirements for the GSEs that will impede credit unions ability to sell their mortgages; urge FHFA to enhance its liquidity and capital requirements for non-bank sellers and servicers; support Congress taking action through legislation to establish a process for these legacy LIBOR contracts to be appropriately updated; support the Boards efforts to ease the transition to new regulatory standards for community institutions by adopting more flexible standards for measuring asset growth; urge FRB to clarify and extend the scope of Regulation II relief under the IFR to account for new stimulus payments; express concerns about the various product and program constraints contained in recent FHFA-Treasury amendments to the Preferred Stock Purchase Agreements (PSPAs) for Fannie Mae and Freddie Mac; supports the 15-month delay of the General QM definition; urge Bureau to expand access to the National Mortgage Database (NMDB) for market participants; urge FHFA to make necessary adjustments to the PSPAs for credit unions to utilize the GSE Patch until October 2022; support extension of the GSE Patch to minimize market disruptions