Farm System Reform Act of 2021

H.R. 1466 - Safe RESEARCH Act H.R. 1827 - Pausing Enhanced Pandemic Pathogen Research Act of 2023 H.R. 4421 - Preparing for All Hazards and Pathogen Reauthorization Act H.R. 4002 - Relieving Economic Strain to Enhance American Resilience and Competitiveness in Higher Education and Research Act H.R.5933 - DETERRENT Act H.R.5404 - Countering Chinese Espionage Reporting Act S. 289 - Genomics Data Security Act H.R. 2670 - National Defense Authorization Act for FY24 (NDAA) S. 2226 - National Defense Authorization Act for FY24 (NDAA) S. 2333 - Pandemic and All Hazards Preparedness Reauthorization Act S. ____ - CHIPS 2.0 S. 1351 - Safeguarding American Innovation Act (117th Congress) S.3362 - DETERRENT Act S.2714 - CREATE AI Act of 2023 -- regarding research-related funding and policy issues affecting higher education institutions and their faculty and students.

Client expense: $74,678 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), SENATE

H.R. 1466 - Safe RESEARCH Act H.R. 1827 - Pausing Enhanced Pandemic Pathogen Research Act of 2023 H.R. 4421 - Preparing for All Hazards and Pathogen Reauthorization Act H.R. 4002 - Relieving Economic Strain to Enhance American Resilience and Competitiveness in Higher Education and Research Act S. 289 - Genomics Data Security Act H.R. 2670 - National Defense Authorization Act for FY24 (NDAA) S. 2226 - National Defense Authorization Act for FY24 (NDAA) S. 2333 - Pandemic and All Hazards Preparedness Reauthorization Act S. ____ - CHIPS 2.0 S. 1351 - Safeguarding American Innovation Act (117th Congress) -- regarding research-related funding and policy issues affecting higher education institutions and their faculty and students.

Client expense: $82,292 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), SENATE

H.R. 1466 - Safe RESEARCH Act H.R. 1827 - Pausing Enhanced Pandemic Pathogen Research Act of 2023 H.R. 4421 - Preparing for All Hazards and Pathogen Reauthorization Act H.R. 2670 - National Defense Authorization Act for FY24 (NDAA) S. 289 - Genomics Data Security Act S. 2226 - National Defense Authorization Act for FY24 (NDAA) S. 2333 - Pandemic and All Hazards Preparedness Reauthorization Act S. ____ - CHIPS 2.0 S. 1351 - Safeguarding American Innovation Act (117th Congress) -- regarding research-related funding and policy issues affecting higher education institutions and their faculty and students.

Client expense: $34,849 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), SENATE

Legislation S.1251 - Growing Climate Solutions Act of 2021 H.R.2820 - Growing Climate Solutions Act of 2021 Farm Bill - Agriculture Improvement Act of 2023 (no bill number yet) H.R.2534/S.1072 - Climate Stewardship Act H.R.2803/ S.1337 - Agriculture Resilience Act H.R.4421/S.2332 - Farm System Reform Act H.R.1393/S.300 - Justice for Black Farmers Act

Client expense: $220,803 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 4239/S.2597 Healthy Dog Importation Act S. 3678/H.R. 8432 Beagle Brigade Act of 2022, all provisions H.R. 4421/S. 2332 Farm Systems Reform Act of 2022, all provisions 2023 Farm Bill Reauthorization

Client expense: Not reported · Firm income: $300,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Legislation S.1251 - Growing Climate Solutions Act of 2021 H.R.2820 - Growing Climate Solutions Act of 2021 Farm Bill - Agriculture Improvement Act of 2023 (no bill number yet) H.R.2534/S.1072 - Climate Stewardship Act H.R.2803/ S.1337 - Agriculture Resilience Act H.R.4421/S.2332 - Farm System Reform Act H.R.1393/S.300 - Justice for Black Farmers Act

Client expense: $219,364 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve, and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Leadership for Bank Regulatory Agencies (Administration, Congress, and the Agencies) Recent nominees have held extreme views on the banking system and financial services and their nominations have increasingly caused unproductive political wrangling. Nominees should be qualified, hold reasonable positions, be willing to work collegially and cooperatively with colleagues and counterparts, serve the best interests of the banking and financial system and economy, and clearly understand the vital importance of and support community banks. Fintechs and Innovation in Financial Services (Congress and the Agencies) Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Special Purpose National Banks (SPNBs) (OCC) SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. SBA Direct Lending (Congress) Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Financial Inclusion (Congress and the Agencies) CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking (Congress) Public banking (i.e., publicly-owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) (FASB and the Agencies) Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements fall disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB) CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include including returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Bank Merger Activity (Congress and the Agencies) New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and FDIC) Legislation and Regulation - H.R. 5912 - Close the ILC Loophole Act (all sections) which is legislation to reform the regulation of industrial loan companies (ILCs) and their parent companies to provide for consolidated federal supervision (House) H.R. 4421 - America COMPETES Act of 2022 (in conference committee/reconciliation) H.R. 1996 - The SAFE Banking Act which permits the banking of cannabis related businesses in states where it is legal (House and Senate) H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) H.R. 7768 - Farm Credit Administration Independence Authority Act (all sections) which is legislation to exempt the Farm Credit System from being regulated by the CFPB and from compliance with Section 1071 of the Dodd-Frank Act - small business data collection (House) H.R. 2543 - Federal Reserve Racial and Economic Equity Act - Amendment to include H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Letters - Comment Letter to the Federal Reserve System regarding: Supplemental Notice and request for Comments, Guidelines for Evaluating Account and Service Requests - Docket No. OP-1747 (Federal Reserve) Comment Letter to the FDIC regarding: Statement of Principles for Climate-Related Financial Risk Management for Large Financial Institutions - RIN 3064-ZA32 (FDIC) Comment Letter to the Federal Reserve regarding: Money and Payments: The Digital Dollar in the Age of Digital Transformation (Federal Reserve) Comment Letter to the FDIC regarding: Guidelines for Appeals of Material Supervisory Determinations - RIN 3064-ZA20 (FDIC) Action Alerts - Action Alert regarding: Expanded Credit Union Powers / H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Miscellaneous - Comment Letter to the CFPB about Fees Imposed by Providers of Financial Products or Services (FDIC and House) Application to CFPBs regulatory sandbox (CFPB) Comment Letter to the Federal Reserve about Money and Payments: The Digital Dollar in the Age of Digital Transformation (House)

CBAI 2022 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. Independent Community Bankers of Americas Legislative and Regulatory Agenda for the Second Session of the 117th Congress CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, SARs, and the CBLR) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. An exit fee should be imposed on these acquisitions. This escalation of credit unions abusing of their tax-exemption should prompt Congress to act now. This abuse is an existential threat to community banks and the communities they serve. Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce. They pose risks to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole permits their holding companies from being supervised and regulated by the Federal Reserve, and must be closed. Federal Reserves Role in Payments System Improvement (FedNow Service) A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must cooperate on a joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety and should be permitted. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, these firm should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. Community Bank Positions on New and Emerging Issues - Leadership for Bank Regulatory Agencies (Administration, Congress, and the Agencies) Recent nominees have held extreme views on the banking system and financial services and their nominations have increasingly caused unproductive political wrangling. Nominees should be qualified, hold reasonable positions, be willing to work collegially and cooperatively with colleagues and counterparts, serve the best interests of the banking and financial system and economy, and clearly understand the vital importance of and support community banks. Fintechs and Innovation in Financial Services (Congress and the Agencies) Financial innovation presents community banks with challenges and opportunities which they are rising to meet. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose any unreasonable requirements, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Special Purpose National Banks (SPNBs) (OCC) SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Digital Assets - Crypto Currency, Central Bank Digital Currency (CBDC), and Stablecoins (Congress and the Agencies) The risks posed by digital assets are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry (i.e. disintermediation.). They also pose threats to the privacy and security of consumers and small business. Of great concern is that there is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments, and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must cooperate and collaborate in the development and implementation of a comprehensive approach to ensure a consistent Federal regulatory framework that does not permit digital assets to threaten the essential and highly successful business model of regulated and responsible community banks. IRS Reporting Plan (Administration, Congress and Treasury) The various proposed IRS reporting requirements are unprecedented, misguided, raises serious concerns about government overreach, and is an invasion of their financial privacy. If implemented, they will damage the trusted and beneficial relationship between community banks and their customers. If the IRS wants to ensure greater compliance with tax laws, it can be accomplished by more appropriately using the existing tools and the wealth of information it currently possesses. SBA Direct Lending (Congress) Community banks and the SBA have a long, beneficial, and cooperative private sector/public sector relationship, where SBA does not compete with banks in lending to small businesses. Direct SBA lending would violate this tradition. Community banks are far superior in establishing and prudently underwriting commercial lending relationships. The SBA originating and disbursing 7(a) loans will put billions of taxpayer dollars at risk of loss. Financial Inclusion (Congress and the Agencies) CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the proper role of government to provide banking services direct to individuals either through the Federal Reserve, state-owned public banks, or the U.S. Postal Service. Providing banking services to individuals and businesses is the proper role of the private-sector banking system. Government can assist the private sector in financial inclusion efforts especially to low- and middle-income consumers, which are those most likely to be un- or underbanked. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Public Banking (Congress) Public banking (i.e., publicly-owned banks) is misguided and is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) (FASB and the Agencies) Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing (CFPB) Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and to be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection (CFPB) Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of these collection and reporting requirements fall disproportionately hard on community banks, and community banks should be provided with meaningful exemptions in this rulemaking. Nonsufficient Funds (Overdraft) Policies and Practices (OCC and the CFPB) CBAI does not support overdraft policies and practices that abuse consumers. Policymakers must accept that it is the consumers responsibility to always know their account balance and not write checks or initiate debit transactions that would overdraw their account. The cost for processing overdrafts may include including returning the item or paying the overdraft which creates the equivalent of an unauthorized, unsecured, and interest-free loan. Effectively managing risks associated with overdrafts is a safety and soundness regulatory requirement. Reporting Beneficial Ownership Information (FinCEN) Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax (Congress) Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Climate Risks (Administration, Congress, and the Agencies) CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities including setting hard lending concentration limits on lending to fossil fuel or other carbon-intensive industries, stress testing or scenario analysis based on adverse climate change assumptions, and capital requirements based on climate risks. Community bankers high-contact and relationship-based lending model together with the soon-to-be-implemented Current Expected Credit Loss model, will incorporating material risk assumptions in estimating loan losses - including climate risks. Additional separate climate risk stress testing, concentration limits, and capital requirements for community banks are duplicative and unnecessary. Bank Merger Activity (Congress and the Agencies) New bank merger legislation or regulation should not apply to community banks. Rather, policymakers should seriously consider the impact on our financial system, economy, and American taxpayers by allowing the nations mega banks, which are too big and unable to fail, to become even larger and more interconnected. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and FDIC) Legislation and Regulation - H.R. 5912 - Close the ILC Loophole Act (all sections) which is legislation to reform the regulation of industrial loan companies (ILCs) and their parent companies to provide for consolidated federal supervision (House) H.R. 4421 - America COMPETES Act of 2022 (in conference committee/reconciliation) H.R. 1996 - The SAFE Banking Act which permits the banking of cannabis related businesses in states where it is legal (House and Senate) H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) H.R. 7768 - Farm Credit Administration Independence Authority Act (all sections) which is legislation to exempt the Farm Credit System from being regulated by the CFPB and from compliance with Section 1071 of the Dodd-Frank Act - small business data collection (House) H.R. 2543 - Federal Reserve Racial and Economic Equity Act - Amendment to include H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Letters - Comment Letter to the Federal Reserve System regarding: Supplemental Notice and request for Comments, Guidelines for Evaluating Account and Service Requests - Docket No. OP-1747 (Federal Reserve) Comment Letter to the FDIC regarding: Statement of Principles for Climate-Related Financial Risk Management for Large Financial Institutions - RIN 3064-ZA32 (FDIC) Comment Letter to the Federal Reserve regarding: Money and Payments: The Digital Dollar in the Age of Digital Transformation (Federal Reserve) Comment Letter to the FDIC regarding: Guidelines for Appeals of Material Supervisory Determinations - RIN 3064-ZA20 (FDIC) Action Alerts - Action Alert regarding: Expanded Credit Union Powers / H.R. 7003 - Expanding Financial Access to Underserved Communities Act (all Sections) which is legislation to expand credit union field of membership and commercial lending powers (House) Miscellaneous - Comment Letter to the CFPB about Fees Imposed by Providers of Financial Products or Services (FDIC and House) Application to CFPBs regulatory sandbox (CFPB) Comment Letter to the Federal Reserve about Money and Payments: The Digital Dollar in the Age of Digital Transformation (House)

Pandemic relief agriculture HR 4421/S 2332 Country of origin labeling Antitrust enforcement livestock markets S 949 Build Back Better reconciliation bill

Client expense: Not reported · Firm income: Not reported

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

HR 1492 - Methane Waste Prevention Act of 2021 HR 1503 - Restoring Community Input and Public Protections in Oil and Gas Leasing Act of 2021 HR 1505 - Bonding Reform and Taxpayer Protection Act of 2021 HR 1506 - Transparency in Energy Production Act of 2021 HR 1517 - Ending Taxpayer Welfare for Oil and Gas Companies Act of 2021 HR 1733 - RECLAIM Act HR 1734 - Abandoned Mine Land Fund reauthorization HR 2415 - Program to permanently plug, remediate, and reclaim orphaned wells HR 3585 - REGROW Act HR 4421 - Farm Systems Reform Act HR 5376 - Build Back Better Act: provisions related to rural utilities and fossil fuel resources S 1076 - REGROW Act S 2170 - PEOPLE Act S 4642 - Oil and Gas Bonding Reform and Orphaned Well Remediation Act Issues other than legislation: -Federal leasing moratorium -Surface owner consent policy

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), SENATE

Pandemic relief agriculture HR 4421/S 2332 Country of origin labeling Antitrust enforcement livestock markets S 949 Build Back Better reconciliation bill

Client expense: Not reported · Firm income: Not reported

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

HJR 34 - Providing for congressional disapproval under chapter 8 of title 5, United States Code, of a rule submitted by the Environmental Protection Agency relating to "Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources Review" HR 1492 - Methane Waste Prevention Act of 2021 HR 1503 - Restoring Community Input and Public Protections in Oil and Gas Leasing Act of 2021 HR 1505 - Bonding Reform and Taxpayer Protection Act of 2021 HR 1506 - Transparency in Energy Production Act of 2021 HR 1517 - Ending Taxpayer Welfare for Oil and Gas Companies Act of 2021 HR 1733 - RECLAIM Act HR 1734 - Abandoned Mine Land Fund reauthorization HR 2415 - Program to permanently plug, remediate, and reclaim orphaned wells HR 4421 - Farm Systems Reform Act SJR 14 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources Review" S 2170 - PEOPLE Act S 2332 - Farm Systems Reform Act S 4617 - Environmental Justice Legacy Pollution Cleanup Act S 4642 - Oil and Gas Bonding Reform and Orphaned Well Remediation Act (116th Congress) To be introduced - Forgiveness of Certain Rural Utilities Service Hardship Loans Issues other than legislation: Federal leasing moratorium Federal bonding rules Utility shutoff moratorium

Client expense: Not reported · Firm income: Not reported

Pandemic relief agriculture HR 4421/S 2332 Country of origin labeling S 949 S 1337/HR 2803

Client expense: Not reported · Firm income: Not reported

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