Promoting New and Diverse Depository Institutions Act

H.R. 935/S. 3391, Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2021 H.R. 1087, Shareholder Political Transparency Act of 2021 H.R. 1187, Corporate Governance Improvement and Investor Protection Act H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 1602, Eliminate Barriers to Innovation Act of 2021 H.R. 2025/S. 840, To amend title 28, United States Code, to increase transparency and oversight of third-party litigation funding in certain actions, and for other purposes H.R. 2516, Promoting Diversity and Inclusion in Banking Act of 2021 H.R. 2543, Federal Reserve Racial and Economic Equity Act H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2570, Climate Risk Disclosure Act of 2021 H.R. 2620, Investor Choice Act of 2021 H.R. 2990/S. 3931, Gig Worker Equity Compensation Act H.R. 3007, Disclosure of Tax Havens and Offshoring Act H.R. 3448/S. 4992, Helping Startups Continue to Grow Act H.R. 3454, Modernizing Disclosures for Investors Act H.R. 3843, Merger Filing Fee Modernization Act of 2022 H.R. 4227/S. 3914, Developing and Empowering our Aspiring Leaders Act H.R. 4277, Overdraft Protection Act of 2021 H.R. 4345, Financial Services and General Government Appropriations Act, 2022 H.R. 4521, America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength (America COMPETES) Act of 2022, including provisions related to House Amendment 218 H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate (LIBOR) Act of 2021 H.R. 4773, Consumer Financial Protection Commission Act H.R. 5128/S. 3503, Expanding Access to Capital for Rural Job Creators Act H.R. 5525, Establishing New Authorities for Businesses Laundering and Enabling Risks to Security (ENABLERS) Act H.R. 5586/S. 3056, Prohibiting IRS Financial Surveillance Act H.R. 5598/S. 3961, Access to Small Business Investor Capital Act H.R. 5648/S. 3022, Stop Wall Street Looting Act H.R. 5795/S. 3097, Main Street Growth Act H.R. 5910, Holding SPACs Accountable Act of 2021 H.R. 5911, Fair Hiring in Banking Act H.R. 7151, Ensuring Sound Guidance Act H.R. 7900, National Defense Authorization Act for Fiscal Year 2023 H.R. 7977, Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 8254/S. 4685, Financial Services and General Government Appropriations Act, 2023 H.R. 8521, Investor Democracy is Expected (INDEX) Act S. 479, Lifting Our Communities through Advance Liquidity for (LOCAL) Infrastructure Act S. 2417, Credit Access and Inclusion Act of 2021 S. 2508, Veterans and Consumers Fair Credit Act S. 3410, The Consumer Protection and Due Process Act S. 3755, Arbitration Fairness for Consumers Act S. 3921, Equal Opportunity for all Investors Act S. 3923, Dodd-Frank Material Disclosure Improvement Act S. 3930, Administrative Enforcement Fairness Act of 2022 S. 3939, Small Entrepreneurs' Empowerment and Development (SEED) Act of 2022 S. 3967, Improving Crowdfunding Opportunities Act S. 3976, Expanding American Entrepreneurship Act S. 4241, Investor Democracy is Expected (INDEX) Act S. 5005, Mandatory Materiality Requirement Act of 2022 Draft legislation titled Jumpstart our Business Startups (JOBS) Act 4.0 of 2022 Draft legislation titled Mandatory Materiality Requirement Act of 2022 Potential legislation to foster economic growth and job creation through capital formation Potential legislation to further economic growth through environmental, social, and governance factors Potential legislation to make changes to the Exchange Act Rule 14a-8 shareholder proposal process Potential legislation to hold proxy voting advice businesses accountable Potential legislation to require the SEC to consider additional standards in the rulemaking process Potential legislation to study the term small entity Potential legislation regarding a new regulatory framework for stablecoins Potential legislation dealing with third party litigation financing and lawsuit lending SEC Money Market Fund Reforms (86 Fed. Reg. 7,248, December 15, 2021) Proposed Rule, Securities and Exchange Commission; Prohibition Against Fraud, Manipulation, or Deception in Connection with Security-Based Swaps, Prohibition against Undue Influence over Chief Compliance Officers, Position Reporting of Large Security-Based Swap Positions (87 Fed. Reg. 6,652-6,706, February 4, 2022) Proposed rule on Enhancement and Standardization of Climate-Related Disclosures for Investors (87 Fed. Reg. 21,334-21,473, April 11,2022) Proposed Rule, Securities and Exchange Commission; Enhanced Disclosures by Certain Investment Advisers and Investment Companies About Environmental, Social, and Governance Investment Practices (87 Fed. Reg. 36,654-36,761, June 17, 2022) Proposed Rule, Securities and Exchange Commission; Investment Company Names (87 Fed. Reg. 36,594-36,651, June 17,2022) Request for Comment on Certain Information Providers Acting as Investment Advisers; Securities and Exchange Commission (87 Fed. Reg. 37,254-37,262, June 22, 2022) Request for Comment, Bureau of Consumer Financial Protection; Agency Information Collection Activities, Report of Terms of Credit Card Plans (Form FR 2572) and Consumer and College Credit Card Agreements (87 Fed. Reg. 50,851-50,852, August 18, 2022) Proposed Rule, Commodity Futures Trading Commission and Securities and Exchange Commission; Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers (87 Fed. Reg. 53,832-53,985 , September 1, 2022) Proposed Rule, Securities and Exchange Commission; Resubmission of Comments and Reopening of Comment Periods for Several Rulemaking Releases Due to a Technological Error is Receiving Certain Comments (87 Fed. Reg. 63,016-63,017, October 18, 2022) SEC Proposed Rule on ESG Disclosures for Investment Advisers and Investment Companies (87 Fed. Reg. 36,654 - 36,761, August 16, 2022) Request for Comment, Securities and Exchange Commission; Draft 2022-2026 Strategic Plan for Securities and Exchange Commission (87 Fed. Reg. 53,040, August 30, 2022) Request for Information, Commodity Futures Trading Commission; Climate-Related Financial Risk (87 Fed. Reg. 34,856-34,862, June 8, 2022) Various issues relating to SEC Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; Public Company Accounting Oversight Board (PCAOB); CFTCs de minimis Exception for Swap Dealers; Securities and Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); qualified mortgage definition under the Truth in Lending Act (P.L. 90-321) (Regulation Z); Financial Stability Oversight Council and the designation of Nonbank Financial Firms as systemically important; Federal Reserve Systems Large Institution Supervision Coordinating Committee; potential housing finance reform legislation; enforcement of Securities and Exchange Commission penalties; potential repeal of the State and Local Tax (SALT) Cap; federal interest rate authority; Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) reform; electronic consent-based SSN Verification Service (eCBSV); environmental, social, and governance (ESG) enforcement; information Collection under the Community Reinvestment Act (CRA); potential Financial Transaction Tax (FTT); potential Treasury Department proposal relating to tax reporting by banks; investment company cross trading; potential money market fund reform measures; resolutions to establish task forces on Artificial Intelligence and Financial Technology in the House Committee on Financial Services; transition to the secured overnight financing rate; implementation of SEC Rule 15c2-11; Department of Labor fiduciary advice exemption: PTE 2020-02; benefits of risk-based pricing; mobile disclosures; Federal Trade Commission issues: Freedom of Information Act Requests, Penalty Offense Authority, Zombie Voting, and overall direction of the Commission under Chair Lina Khan; Tax Reporting Proposal by the Department of the Treasury related to a $600 or more annual account threshold; Amendment to the FY22 National Defense Authorization Act related to credit reporting; Climate-Related Financial Risk Management for Large Banks; House Committee on Financial Services request for information related to Russia sanctions; Consumer Financial Protection Bureau (CFPB) regulatory sandbox for disclosures; CFPB Policy Fellowship program; CFPB amendment of its Supervision and Examination Manual; CFPB conflation of Distinct Statutory Concepts of Unfairness and Discrimination Promoting the importance of appropriate length of SEC Comment Periods; Internal Revenue Service; Priority Guidance Plan; Compliance Assistance Release, Department of Labor; 401(k) Plan Investments in Cryptocurrencies Request for Information, Consumer Financial Protection Bureau; Fees Imposed by Providers of Consumer Financial Products or Services; Notice of Inquiry, Federal Communications Commission; In the Matter of Implementing the Infrastructure Investment and Jobs Act: Prevention and Elimination of Digital Discrimination; (GN Docket No. 22-69); Consumer Financial Protection Bureau; Enhancing Public Data on Auto Lending; Document ID CFPB-2022-0075-0001 (November 17, 2022); Proposed Rule, Securities and Exchange Commission; Open-End Fund Liquidity Risk Management Programs and Swing Pricing, Form N-PORT; Outsourcing by Investment Advisers (File Nos. S7-26-22, S7-25-22; RIN 3325-AM98; RIN 3235-AN18, November 2, 2022); EU sustainable finance action plan and incorporating ESG factors into financial services; EU requirements for supply chain due diligence and disclosure; EU review of Alternative Investment Fund Managers Directive; EU review of prudential regime for investment firms; implementation and enforcement of Regulation Best Interest by the Securities and Exchange Commission; changes in the enforcement policies of the Securities and Exchange Commission; activity of the Financial Stability Oversight Council and recommendations on macro-prudential regulation; clarification in the regulatory treatment of digital assets by the Securities and Exchange Commission and the Commodity Futures Trading Commission; EU Money Market Fund Regulation, legislative review; electronic delivery of certain investment documents and disclosures; Financial Stability Board recommendations on money market fund reform; IOSCO recommendations on sustainability-related practices, polices, procedures, and disclosure in asset management; Office of Financial Research (OFR) discussions on FSOC Report on Climate-Related Financial Risk; Written responses regarding requests for comment resulting from the March 9, 2022 Executive Order on Ensuring Responsible Development of Digital Assets; FinCEN Implementation of the Beneficial Ownership Requirements of the Corporate Transparency Act (P.L. 116-283)

Client expense: $20,990,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2561, Promoting Access to Capital in Unbanked Communities Act of 2021 S. 910, SAFE Banking Act S.J.RES.15, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders." H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate LIBOR Act H.R. 5189, Member Business Loan Expansion Act S. 2508, Veterans and Consumer Fair Credit Act Perlmutter Amendment (H.Amdt.97) to H.R. 4350, National Defense Authorization Act of 2022 H.R. 2989, Financial Transparency Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act Coin Circulation S. 3779, Adjustable Interest Rate LIBOR Act H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking. H.R. 2543, Federal Reserve Racial and Economic Equity Act UDAAP Supervisory Policies and Adjudication Procedures Issues impacting the modernization of the Community Reinvestment Act Deposit Insurance Assessment Rates S.4674, Credit Card Competition Act H.R. 8874, Credit Card Competition Act H.R. 8485, Expanding Access to Credit through Consumer-Permissioned Data Act S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes

H.R. 1996 SAFE Banking Act H.R. 2543 Federal Reserve Racial and Economic Equity Act, Credit Union Provisions & Community Bank Amendment Amendment #6 to H.R. 2543, to repeal Section 1071 of the Dodd-Frank Act Sec. 521, 522, 523 & 524 of H.R.2543 - Federal Reserve Racial and Economic Equity Act H.R. 2561 Promoting Access to Capital in Underbanked Communities Act of 2021 H.R. 3009 Improving Language Access in Mortgage Servicing H.R. 4277 Overdraft Protection Act H.R. 4345 FY 2022 Financial Services and General Government Appropriation - Postal Banking Pilot Program H.R. 4590 Promoting New and Diverse Depository Institutions Act H.R. 5376 Inflation Reduction Act of 2022 (Build Back Better) H.R. 5886 Prohibit IRS Financial Surveillance Act H.R. 5912 Close ILC Loophole Act H.R. 6037 Prohibit SBA 7(a) Direct Lending H.R. 6054 Small Business Lending Disclosure Act H.R. 6732 Small LENDER Act H.R. 6739 Business Loan Privacy Act H.R. 6802 Prevent Racial Profiling in Lending Act H.R. 6814 Small Business Fair Debt Collection Practices Act H.R. 6889 The Credit Union Board Modernization Act H.R. 7003 Expanding Financial Access for Underserved Communities Act H.R. 7412 Transparency in CFPB Cost-Benefit Analysis Act H.R. 7768 Farm Credit Administration Independence Authority Act H.R. 8152 American Data Privacy and Protection Act H.R. 8443 Making the CFPB Accountable Act H.R. 8833 The Making Communities Stronger Through the Community Reinvestment Act H.R. 8874 Credit Card Competition Act H.R. 8950 the Digital Commodities Consumer Protection Act of 2022 S. 910 SAFE Banking Act S. 1684 Federal Home Loan Banks Mission Implementation Act S. 3056 Prohibit IRS Financial Surveillance Act S. 3382 Protecting Access to Credit for Small Businesses Act S. 3715 E-Sign Modernization Act S. 3954 Ban CBDC S. 4004 Small LENDER Act S. 4356 Lummis-Gillibrand Responsible Financial Innovation Act S. 4522 Transparency in CFPB Cost-Benefit Analysis Act S. 4674 Credit Card Competition Act S. 4831 No CBDC Act Amendments 69 and 70 to FY2023 FSGG Appropriations Bill (Postal banking) Bank Merger Policy BankOn accounts Banking Services Fees Cannabis Banking Central Bank Digital Currency Climate Risk Disclosure Requirements Climate-Related Financial Regulation Community Bank Access to Capital Community Banks on Military Bases Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Consumer Financial Protection Bureau, report of financial services in rural America Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Cybersecurity Requirements Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Supplemental Capital Cryptocurrency Customer Data Access, Implementation of Dodd Frank Act Section 1033 Cybersecurity Data Privacy Discussion Draft Data Security, Breaches and Privacy De Novo Bank Formation Dodd Frank Act 1071- Small Business Loan Data Collection Digital Assets Regulation Durbin Amendment on Interchange; Extension to Credit Cards FDIC Deposit Insurance Assessments FDIC Premium Increases FDIC Supervisory Appeals Review Committee and Policy Financial Data Privacy Discussion Draft Fintech Regulatory Requirements Fintech/Banking Relationships Flood Insurance Reauthorization Industrial Loan Corporation Loophole Reforms/ Rakuten (ILC) et al, Deposit Insurance Applications Interchange Interest Rate Caps Minority Depository Institutions Issues National Defense Authorization Act, Opposition to Inclusion of Credit Card Competition Act as an Amendment National Defense Authorization Act, Report Language on Financial Institution leases on military bases OCC Proposed Payments Charter Overdraft Fees Overdraft Protection P2P Payment Applications Fraud Postal Banking Protecting Consumers from Payment Scams Act (draft) SAFE Banking Act, support for inclusion in America COMPETES Act Conference SBA 7(a) Loan Program Funding and Terms SBA Direct 7(a) Direct Lending Secure Notarization Small Business Loan Data Collection--CFPB Implementation of Dodd-Frank Act Section 1071 Stablecoins Stablecoin Innovation and Protection Act of 2022 (draft) Stablecoin Legislation - Waters-McHenry Discussion Draft Stablecoin TRUST Act (draft) Unfair, deceptive, or abusive acts and practices (UDAAP)

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.

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.

H.R. 935, Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2021 H.R. 1087, Shareholder Political Transparency Act of 2021 H.R. 1187, Corporate Governance Improvement and Investor Protection Act H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 1602, Eliminate Barriers to Innovation Act of 2021 H.R. 2025/S. 840, To amend title 28, United States Code, to increase transparency and oversight of third-party litigation funding in certain actions, and for other purposes H.R. 2516, Promoting Diversity and Inclusion in Banking Act of 2021 H.R. 2543, Federal Reserve Racial and Economic Equity Act H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2570, Climate Risk Disclosure Act of 2021 H.R. 2620, Investor Choice Act of 2021 H.R. 3007, Disclosure of Tax Havens and Offshoring Act H.R. 3448, Helping Startups Continue to Grow Act H.R. 3454, Modernizing Disclosures for Investors Act H.R. 3843, Merger Filing Fee Modernization Act of 2022 H.R. 4277, Overdraft Protection Act of 2021 H.R. 4345, Financial Services and General Government Appropriations Act, 2022 H.R. 4521, America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength (America COMPETES) Act of 2022, including provisions related to House Amendment 218 H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate (LIBOR) Act of 2021 H.R. 4773, Consumer Financial Protection Commission Act H.R. 5586/S. 3056, Prohibiting IRS Financial Surveillance Act H.R. 5648/S. 3022, Stop Wall Street Looting Act H.R. 5910, Holding SPACs Accountable Act of 2021 H.R. 5911, Fair Hiring in Banking Act H.R. 7151, Ensuring Sound Guidance Act H.R. 7900, National Defense Authorization Act for Fiscal Year 2023 H.R. 7977, Promoting Opportunities for Non-Traditional Capital Formation Act H.R. 8254/S. 4685, Financial Services and General Government Appropriations Act, 2023 H.R. 8521, Investor Democracy is Expected (INDEX) Act S. 479, Lifting Our Communities through Advance Liquidity for (LOCAL) Infrastructure Act S. 2417, Credit Access and Inclusion Act of 2021 S. 2508, Veterans and Consumers Fair Credit Act S. 2621, Modernization of Derivatives Tax Act of 2021 S. 3410, The Consumer Protection and Due Process Act S. 3755, Arbitration Fairness for Consumers Act S. 3844, Economic Continuity and Stability Act S. 3914, Developing and Empowering our Aspiring Leaders Act of 2022 S. 4241, Investor Democracy is Expected (INDEX) Act Draft legislation titled Jumpstart our Business Startups (JOBS) Act 4.0 of 2022 Draft legislation titled Mandatory Materiality Requirement Act of 2022 Potential legislation to foster economic growth and job creation through capital formation Potential legislation to further economic growth through environmental, social, and governance factors Potential legislation to make changes to the Exchange Act Rule 14a-8 shareholder proposal process Potential legislation to hold proxy voting advice businesses accountable Potential legislation to expressing a sense of Congress reaffirming the Supreme Court materiality standard Potential legislation to require the SEC to consider additional standards in the rulemaking process Potential legislation to study the term small entity Potential legislation regarding a new regulatory framework for stablecoins Potential legislation dealing with third party litigation financing and lawsuit lending Potential legislation dealing with securities litigation Nomination of Mark Uyeda to be Commissioner of the U.S. Securities and Exchange Commission (SEC) Proposed rule regarding SEC Enhanced Reporting of Proxy Votes by Registered Management Investment Companies; Reporting of Executive Compensation Votes by Institutional Investment Managers Proposed Rule (86 Fed. Reg. 57,478-57,524, October 15, 2021) Proposed rule regarding Position Reporting of Large Security-Based Swap Positions (87 Fed. Reg. 6,652-6,706, December 15, 2021) SEC Money Market Fund Reforms (86 Fed. Reg. 7,248, December 15, 2021) Proposed rules regarding amendments to Form PF (87 Fed. Reg. 9,106-9,235, January 26, 2022) Proposed rule regarding Share Repurchase Disclosure Modernization (87 Fed. Reg. 8,443-8,472, February 15, 2022) Proposed Rule, Securities and Exchange Commission; Prohibition Against Fraud, Manipulation, or Deception in Connection with Security-Based Swaps, Prohibition against Undue Influence over Chief Compliance Officers, Position Reporting of Large Security-Based Swap Positions (87 Fed. Reg. 6,652-6,706, February 4, 2022) Proposed rule on Enhancement and Standardization of Climate-Related Disclosures for Investors (87 Fed. Reg. 21,334-21,473, April 11,2022) Proposed Rule, Securities and Exchange Commission; Enhanced Disclosures by Certain Investment Advisers and Investment Companies About Environmental, Social, and Governance Investment Practices (87 Fed. Reg. 36,654-36,761, June 17, 2022) Proposed Rule, Securities and Exchange Commission; Investment Company Names (87 Fed. Reg. 36,594-36,651, June 17,2022) Proposed Rule, Securities and Exchange Commission; Share Repurchase Disclosure Modernization (87 Fed. Reg. 8,443-8,472, April 1, 2022) Proposed Rule, Securities and Exchange Commission; Substantial Implementation, Duplication, and Resubmission of Shareholder Proposals Under Exchange Act Rule 14a-8 (87 Fed. Reg. 45,052-45,075. July 27, 2022) Request for Comment on Certain Information Providers Acting as Investment Advisers; Securities and Exchange Commission (87 Fed. Reg. 37,254-37,262, June 22, 2022) Request for Comment, Bureau of Consumer Financial Protection; Agency Information Collection Activities, Report of Terms of Credit Card Plans (Form FR 2572) and Consumer and College Credit Card Agreements (87 Fed. Reg. 50,851-50,852, August 18, 2022) Advance Notice of Proposed Rulemaking, Bureau of Consumer Financial Protection; Credit Card Late Fees and Late Payments (87 Fed. Reg. 42,662, July 18, 2022) Joint Notice of Proposed Rulemaking, Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, Federal Reserve System; Community Reinvestment Act (87 Fed. Reg. 33,884-34,066, June 3, 2022) Request for Comments, Department of the Treasury; Ensuring Responsible Development of Digital Assets (87 Fed. Reg. 40,881-40,883, July 8, 2022) Request for Comment, International Trade Administration; Developing a Framework on Competitiveness of Digital Asset Technologies (87 Fed. Reg. 30450- 30452, May 19, 2022) Various issues relating to SEC Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; Public Company Accounting Oversight Board (PCAOB); CFTCs de minimis Exception for Swap Dealers; Securities and Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); qualified mortgage definition under the Truth in Lending Act (P.L. 90-321) (Regulation Z); Financial Stability Oversight Council and the designation of Nonbank Financial Firms as systemically important; Federal Reserve Systems Large Institution Supervision Coordinating Committee; potential housing finance reform legislation; enforcement of Securities and Exchange Commission penalties; potential repeal of the State and Local Tax (SALT) Cap; federal interest rate authority; Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) reform; electronic consent-based SSN Verification Service (eCBSV); environmental, social, and governance (ESG) enforcement; information Collection under the Community Reinvestment Act (CRA); potential Financial Transaction Tax (FTT); potential Treasury Department proposal relating to tax reporting by banks; investment company cross trading; potential money market fund reform measures; resolutions to establish task forces on Artificial Intelligence and Financial Technology in the House Committee on Financial Services; transition to the secured overnight financing rate; implementation of SEC Rule 15c2-11; Department of Labor fiduciary advice exemption: PTE 2020-02; benefits of risk-based pricing; mobile disclosures; Federal Trade Commission issues: Freedom of Information Act Requests, Penalty Offense Authority, Zombie Voting, and overall direction of the Commission under Chair Lina Khan; Tax Reporting Proposal by the Department of the Treasury related to a $600 or more annual account threshold; Amendment to the FY22 National Defense Authorization Act related to credit reporting; Climate-Related Financial Risk Management for Large Banks; House Committee on Financial Services request for information related to Russia sanctions; CFPB Policy Fellowship program; CFPB amendment of its Supervision and Examination Manual; CFPB conflation of Distinct Statutory Concepts of Unfairness and Discrimination; Promoting the importance of appropriate length of SEC Comment Periods; Internal Revenue Service; Priority Guidance Plan; Compliance Assistance Release, Department of Labor; 401(k) Plan Investments in Cryptocurrencies Request for Information, Consumer Financial Protection Bureau; Fees Imposed by Providers of Consumer Financial Products or Services; Notice of Inquiry, Federal Communications Commission; In the Matter of Implementing the Infrastructure Investment and Jobs Act: Prevention and Elimination of Digital Discrimination; (GN Docket No. 22-69); EU sustainable finance action plan and incorporating ESG factors into financial services; EU review of Alternative Investment Fund Managers Directive; EU review of prudential regime for investment firms; implementation and enforcement of Regulation Best Interest by the Securities and Exchange Commission; changes in the enforcement policies of the Securities and Exchange Commission; activity of the Financial Stability Oversight Council and recommendations on macro-prudential regulation; clarification in the regulatory treatment of digital assets by the Securities and Exchange Commission and the Commodity Futures Trading Commission; implementation and enforcement of proxy advisory firm regulations finalized in 2020; implementation and enforcement of SEC 14a-8 shareholder proposal process reforms finalized in 2020; EU Money Market Fund Regulation, legislative review; electronic delivery of certain investment documents and disclosures; implementation of beneficial ownership reporting requirements under the National Defense Authorization Act FY2021 (P.L. 116-283); implementation of the Social Security Administrations Electronic Consent Based Social Security Number Verification System Service; Financial Stability Board recommendations on money market fund reform; IOSCO recommendations on sustainability-related practices, polices, procedures, and disclosure in asset management; Office of Financial Research (OFR) discussions on FSOC Report on Climate-Related Financial Risk; staff legal guidance at the SEC concerning no-action letters on shareholder proposals with broad societal impact (Staff Legal Bulletin 14L-CF); SEC Reforms to regulations related to Cybersecurity Disclosures; SEC Reforms to regulations related to Human Capital Management Disclosures; SEC Reforms to regulations related to proxy voting advice businesses; SEC request for information on digital engagement practices; Written responses regarding requests for comment resulting from the March 9, 2022 Executive Order on Ensuring Responsible Development of Digital Assets; SEC Proposed Rule amending 10b5-1; SEC Proposed Rule on Private Fund Advisers; Documentation of Registered Investment Adviser Compliance Reviews; SEC Amended Rule 15c2-11, applicability to 144A securities; SEC Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors; SEC Substantial Implementation, Duplication, and Resubmission of Shareholder Proposals Under Exchange Act Rule 14a-8; PCAOB 2022-2026 Draft Strategic Plan; SEC FY 22-26 Strategic Plan; FinCEN Implementation of the Beneficial Ownership Requirements of the Corporate Transparency Act (P.L. 116-283)

Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2561, Promoting Access to Capital in Unbanked Communities Act of 2021 S. 910, SAFE Banking Act S.J.RES.15, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders." H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate LIBOR Act H.R. 5189, Member Business Loan Expansion Act S. 2508, Veterans and Consumer Fair Credit Act Perlmutter Amendment (H.Amdt.97) to H.R. 4350, National Defense Authorization Act of 2022 H.R. 2989, Financial Transparency Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act Coin Circulation S. 3779, Adjustable Interest Rate LIBOR Act H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking. H.R. 2543, Federal Reserve Racial and Economic Equity Act UDAAP Supervisory Policies and Adjudication Procedures Issues impacting the modernization of the Community Reinvestment Act Deposit Insurance Assessment Rates S.4674, Credit Card Competition Act H.R. 8874, Credit Card Competition Act H.R. 8485, Expanding Access to Credit through Consumer-Permissioned Data Act S.4760, Digital Commodities Consumer Protection Act of 2022 Merchant Category Codes

H.R. 1996 SAFE Banking Act H.R. 2543 Federal Reserve Racial and Economic Equity Act, Credit Union Provisions & Community Bank Amendment Amendment #6 to H.R. 2543, to repeal Section 1071 of the Dodd-Frank Act Sec. 521, 522, 523 & 524 of H.R.2543 - Federal Reserve Racial and Economic Equity Act H.R. 2561 Promoting Access to Capital in Underbanked Communities Act of 2021 H.R. 3009 Improving Language Access in Mortgage Servicing H.R. 4277 Overdraft Protection Act H.R. 4345 FY 2022 Financial Services and General Government Appropriation - Postal Banking Pilot Program H.R. 5376 The Build Back Better Act H.R. 5886 Prohibit IRS Financial Surveillance Act H.R. 5912 Close ILC Loophole Act H.R. 6037 Prohibit SBA 7(a) Direct Lending H.R. 6054 Small Business Lending Disclosure Act H.R. 6307 Protecting Access to Credit for Small Businesses Act H.R. 6732 Small LENDER Act H.R. 6739 Business Loan Privacy Act H.R. 6745 Ensuring Diversity in Community Banking Act H.R. 6802 Prevent Racial Profiling in Lending Act H.R. 6814 Small Business Fair Debt Collection Practices Act H.R. 7003 Expanding Financial Access for Underserved Communities Act H.R. 7022 Strengthening Cybersecurity Act H.R. 7412 Transparency in CFPB Cost-Benefit Analysis Act H.R. 7768 Farm Credit Administration Independence Authority Act H.R. 8152 American Data Privacy and Protection Act S. 910 SAFE Banking Act S. 1684 Federal Home Loan Banks Mission Implementation Act S. 3056 Prohibit IRS Financial Surveillance Act S. 3382 Protecting Access to Credit for Small Businesses Act S. 3409 A bill to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024, and for other purposes. S. 3441 CDFI Bond Guarantee Program Improvement Act S. 3715 E-Sign Modernization Act S. 3745 TAILOR Act S. 3954 Ban CBDC S. 4004 Small LENDER Act S. 4356 Lummis-Gillibrand Responsible Financial Innovation Act Bank Merger Policy Bank Secrecy Act/Anti-Money Laundering Rules/Legislation, including Beneficial Ownership Issue Banking Services Fees Cannabis Banking Central Bank Digital Currency Climate Risk Disclosure Requirements Climate-Related Financial Regulation Community Bank Access to Capital Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Consumer Financial Protection Bureau, report of financial services in rural America Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Cybersecurity Requirements Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Supplemental Capital Cryptocurrency Customer Data Access, Implementation of Dodd Frank Act Section 1033 Cybersecurity Data Security, Breaches and Privacy De Novo Bank Formation Dodd Frank Act 1071- Small Business Loan Data Collection Digital Assets Regulation Durbin Amendment on Interchange; Extension to Credit Cards Emergency Capital Investment Program Expanding Opportunity for Minority Depository Institutions Act (draft) Faster/Instant Payments FDIC Premium Increases FDIC Supervisory Appeals Review Committee and Policy Federal Reserve Accounts for Consumers Financial Data Privacy Discussion Draft Financial Inclusion Fintech Regulatory Requirements Fintech/Banking Relationships Flood Insurance Reauthorization Industrial Loan Corporation Loophole Reforms/ Rakuten (ILC) et al, Deposit Insurance Applications Interchange Interest Rate Caps IRS Reporting of Financial Account Inflows/Outflows Minority Depository Institutions Issues OCC Proposed Payments Charter Overdraft Fees Overdraft Protection Patent Reform Legislation Postal Banking Protecting Consumers from Payment Scams Act (draft) SAFE Banking Act, support for inclusion in America COMPETES Act Conference SBA 7(a) Loan Program Funding and Terms SBA Direct 7(a) Direct Lending Secure Notarization Small Business Loan Data Collection--CFPB Implementation of Dodd-Frank Act Section 1071 Stablecoins Stablecoin Innovation and Protection Act of 2022 (draft) Stablecoin TRUST Act (draft) H.R. 4590 - Promoting New and Diverse Depository Institutions Act H. R. 5376 - Inflation Reduction Act of 2022 (Build Back Better) H.R. 6889 - The Credit Union Board Modernization Act H.R. 8443, Making the CFPB Accountable Act H.R. 8833, the Making Communities Stronger Through the Community Reinvestment Act H.R. 8874, Credit Card Competition Act H.R. 8950, the Digital Commodities Consumer Protection Act of 2022 S. 4522 - Transparency in CFPB Cost-Benefit Analysis Act S. 4674, Credit Card Competition Act S. 4831 No CBDC Act Amendments 69 and 70 to FY2023 FSGG Appropriations Bill (Postal banking) BankOn accounts Community Banks on Military Bases FDIC Deposit Insurance Assessments National Defense Authorization Act, opposition to inclusion of Credit Card Competition Act as an Amendment National Defense Authorization Act, report language on financial institution leases on military bases P2P Payment Applications Fraud Stablecoin Legislation - Waters-McHenry Discussion Draft Unfair, deceptive, or abusive acts and practices (UDAAP)

Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Durbin Interchange Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2561, Promoting Access to Capital in Unbanked Communities Act of 2021 S. 910, SAFE Banking Act S.J.RES.15, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders." H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate LIBOR Act H.R. 5189, Member Business Loan Expansion Act S. 2508, Veterans and Consumer Fair Credit Act Perlmutter Amendment (H.Amdt.97) to H.R. 4350, National Defense Authorization Act of 2022 H.R. 2989, Financial Transparency Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act Coin Circulation S. 3779, Adjustable Interest Rate LIBOR Act H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking. H.R. 2543, Federal Reserve Racial and Economic Equity Act UDAAP Supervisory Policies and Adjudication Procedures Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Durbin Interchange Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2561, Promoting Access to Capital in Unbanked Communities Act of 2021 S. 910, SAFE Banking Act S.J.RES.15, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders." H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate LIBOR Act H.R. 5189, Member Business Loan Expansion Act S. 2508, Veterans and Consumer Fair Credit Act Perlmutter Amendment (H.Amdt.97) to H.R. 4350, National Defense Authorization Act of 2022 H.R. 2989, Financial Transparency Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act Coin Circulation S. 3779, Adjustable Interest Rate LIBOR Act H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act S. 2677, Stop Overdraft Profiteering Act of 2021 S. 4356, Responsible Financial Innovation Act The impact of Environmental, Social and Governance guidance and regulatory proposals on Banking. H.R. 2543, Federal Reserve Racial and Economic Equity Act UDAAP Supervisory Policies and Adjudication Procedures

Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Durbin Interchange Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2561, Promoting Access to Capital in Unbanked Communities Act of 2021 S. 910, SAFE Banking Act S.J.RES.15, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders." H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate LIBOR Act H.R. 5189, Member Business Loan Expansion Act S. 2508, Veterans and Consumer Fair Credit Act Perlmutter Amendment (H.Amdt.97) to H.R. 4350, National Defense Authorization Act of 2022 H.R. 2989, Financial Transparency Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act Coin Circulation S. 3779, Adjustable Interest Rate LIBOR Act H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act

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

H.R. 935, Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2021 H.R. 1087, Shareholder Political Transparency Act of 2021 H.R. 1187, Corporate Governance Improvement and Investor Protection Act H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 1602, Eliminate Barriers to Innovation Act of 2021 H.R. 2025/S. 840, To amend title 28, United States Code, to increase transparency and oversight of third-party litigation funding in certain actions, and for other purposes H.R. 2516, Promoting Diversity and Inclusion in Banking Act of 2021 H.R. 2543, Federal Reserve Racial and Economic Equity Act H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2570, Climate Risk Disclosure Act of 2021 H.R. 2620, Investor Choice Act of 2021 H.R. 3007, Disclosure of Tax Havens and Offshoring Act H.R. 3448, Helping Startups Continue to Grow Act H.R. 3454, Modernizing Disclosures for Investors Act H.R. 4277, Overdraft Protection Act of 2021 H.R. 4345, Financial Services and General Government Appropriations Act, 2022 H.R. 4350, National Defense Authorization Act for Fiscal Year 2022 H.R. 4521, America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength (America COMPETES) Act of 2022, including provisions related to House Amendment 218 H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate (LIBOR) Act of 2021 H.R. 4773, Consumer Financial Protection Commission Act H.R. 5586/S. 3056, Prohibiting IRS Financial Surveillance Act H.R. 5648/S. 3022, Stop Wall Street Looting Act H.R. 5910, Holding SPACs Accountable Act of 2021 H.R. 5911, Fair Hiring in Banking Act H.R. 7977, Promoting Opportunities for Non-Traditional Capital Formation Act S. 479, Lifting Our Communities through Advance Liquidity for (LOCAL) Infrastructure Act S. 2417, Credit Access and Inclusion Act of 2021 S. 2508, Veterans and Consumers Fair Credit Act S. 2621, Modernization of Derivatives Tax Act of 2021 S. 3410, The Consumer Protection and Due Process Act S. 3844, Economic Continuity and Stability Act S. 3914, Developing and Empowering our Aspiring Leaders Act of 2022 S. 4241, INvestor Democracy is EXpected (INDEX) Act Draft legislation titled Jumpstart our Business Startups (JOBS) Act 4.0 of 2022 Draft legislation titled Making appropriations for Financial Services and General Government for the fiscal year ending September 30, 2023, and for other purposes Potential legislation to foster economic growth and job creation through capital formation Potential legislation to further economic growth through environmental, social, and governance factors Potential legislation to speed up the timeline of the Holding Foreign Companies Accountable Act Potential legislation to enshrine SEC threshold ownership requirements for shareholder proposals Potential legislation to require the SEC to study barriers in accessing capital for minority entrepreneurs Potential legislation to expressing a sense of Congress reaffirming the Supreme Court materiality standard Potential legislation to require the SEC to consider additional standards in the rulemaking process Nomination of Mark Uyeda to be Commissioner of the U.S. Securities and Exchange Commission (SEC) Proposed rule regarding SEC Enhanced Reporting of Proxy Votes by Registered Management Investment Companies; Reporting of Executive Compensation Votes by Institutional Investment Managers Proposed Rule (86 Fed. Reg. 57,478-57,524, October 15, 2021) Proposed rule regarding SEC Reporting of Securities Loans (86 Fed. Reg. 69,802-69,853, December 8, 2021) Proposed rule regarding Position Reporting of Large Security-Based Swap Positions (87 Fed. Reg. 6,652-6,706, December 15, 2021) SEC Money Market Fund Reforms (86 Fed. Reg. 7,248, December 15, 2021) Proposed rules regarding amendments to Form PF (87 Fed. Reg. 9,106-9,235, January 26, 2022) Request for Information Regarding Fees Imposed by Providers of Consumer Financial Products or Services, Consumer Financial Protection Bureau; (87 Fed. Reg. 5,801-5,803, February 2, 2022) Request for Comment, Board of Governors of the Federal Reserve System; Framework for the Supervision of Insurance Organizations (87 Fed. Reg. 6,537-6,549, February 4, 2022) Procedural Rule, Request for Comment, Consumer Financial Protection Bureau; Supervisory Authority Over Certain Nonbank Covered Persons Based on Risk Determination; Public Release of Decisions and Orders (87 Fed. Reg. 25397-25398, April 29, 2022) Proposed Rule, Consumer Financial Protection Bureau; Prohibition on Inclusion of Adverse Information in Consumer Reporting in Cases of Human Trafficking (Regulation V) (87 Fed. Reg. 20,771-20,781, April 8, 2022) Proposed Rule, Federal Deposit Insurance Corporation; Rules, Regulations, Guidance, and Statement of Policy on Bank Merger Transactions (87 Fed. Reg. 18,740-18,744, March 31, 2022) Proposed Rule; Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure (87 Fed. Reg. 16,590-16,624, May 9, 2022) Proposed Rule, Securities and Exchange Commission; Private Fund Advisers; Documentation of Registered Investment Adviser Compliance Reviews (87 Fed. Reg. 16,886-16,977, March 24, 2022) Request for Comment, Federal Deposit Insurance Corporation; Statement of Principles for Climate-Related Financial Risk Management for Large Financial Institutions (87 Fed. Reg. 19,507-19,512, April 4, 2022) Various issues relating to SEC Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; Public Company Accounting Oversight Board (PCAOB); CFTCs de minimis Exception for Swap Dealers; Securities and Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); qualified mortgage definition under the Truth in Lending Act (P.L. 90-321) (Regulation Z); Financial Stability Oversight Council and the designation of Nonbank Financial Firms as systemically important; Federal Reserve Systems Large Institution Supervision Coordinating Committee; potential housing finance reform legislation; enforcement of Securities and Exchange Commission penalties; potential repeal of the State and Local Tax (SALT) Cap; federal interest rate authority; Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) reform; electronic consent-based SSN Verification Service (eCBSV); environmental, social, and governance (ESG) enforcement; information Collection under the Community Reinvestment Act (CRA) (P.L. 95-128); potential Financial Transaction Tax (FTT); potential Treasury Department proposal relating to tax reporting by banks; investment company cross trading; potential money market fund reform measures; resolutions to establish task forces on Artificial Intelligence and Financial Technology in the House Committee on Financial Services; transition to the secured overnight financing rate; implementation of SEC Rule 15c2-11; Department of Labor fiduciary advice exemption: PTE 2020-02; benefits of risk-based pricing; mobile disclosures; Federal Trade Commission issues: Freedom of Information Act Requests, Penalty Offense Authority, Zombie Voting, and overall direction of the Commission under Chair Lina Khan; Tax Reporting Proposal by the Department of the Treasury related to a $600 or more annual account threshold; Amendment to the FY22 National Defense Authorization Act related to credit reporting; Climate-Related Financial Risk Management for Large Banks; House Committee on Financial Services request for information related to Russia sanctions; Proposed Rule, Securities and Exchange Commission; Prohibition Against Fraud, Manipulation, or Deception in Connection with Security-Based Swaps, Prohibition against Undue Influence over Chief Compliance Officers, Position Reporting of Large Security-Based Swap Positions; Consumer Financial Protection Bureau (CFPB) activities, including a regulatory sandbox for disclosures; CFPB Policy Fellowship program; CFPB amendment of its Supervision and Examination Manual; CFPB conflation of Distinct Statutory Concepts of Unfairness and Discrimination Promoting the importance of appropriate length of SEC Comment Periods; EU sustainable finance action plan and incorporating ESG factors into financial services; EU review of Alternative Investment Fund Managers Directive; EU review of prudential regime for investment firms; implementation and enforcement of Regulation Best Interest by the Securities and Exchange Commission; changes in the enforcement policies of the Securities and Exchange Commission; activity of the Financial Stability Oversight Council and recommendations on macro-prudential regulation; clarification in the regulatory treatment of digital assets by the Securities and Exchange Commission and the Commodity Futures Trading Commission; implementation and enforcement of proxy advisory firm regulations finalized in 2020; implementation and enforcement of SEC 14a-8 shareholder proposal process reforms finalized in 2020; EU Money Market Fund Regulation, legislative review; electronic delivery of certain investment documents and disclosures; implementation of beneficial ownership reporting requirements under the National Defense Authorization Act FY2021 (P.L. 116-283); implementation of the Social Security Administrations Electronic Consent Based Social Security Number Verification System Service; Financial Stability Board recommendations on money market fund reform; IOSCO recommendations on sustainability-related practices, polices, procedures, and disclosure in asset management; Office of Financial Research (OFR) discussions on FSOC Report on Climate-Related Financial Risk; staff legal guidance at the SEC concerning no-action letters on shareholder proposals with broad societal impact (Staff Legal Bulletin 14L-CF); SEC reforms to regulations related to climate disclosures; SEC reforms to regulations related to Shareholder Proposals; SEC reforms to regulations related to Cybersecurity Disclosures; SEC reforms to regulations related to Human Capital Management Disclosures; SEC reforms to regulations related to Share Repurchase Disclosures; SEC reforms to regulations related to 10b5-1 Disclosure; SEC request for information on digital engagement practices; FinCEN Implementation of the Beneficial Ownership Requirements of the Corporate Transparency Act (P.L. 116-283); SEC Reopening of Comment Period on Pay Versus Performance; SEC Proposed Rule amending 10b5-1; SEC Amended Rule 15c2-11, applicability to 144A securities; SEC Proposed Rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors; SEC prosed rule on private fund advisors; documentation of registered investment adviser compliance reviews; Proposed Rule, Securities and Exchange Commission; Share Repurchase Disclosure Modernization; Proposed Rule, Securities and Exchange Commission; The Enhancement and Standardization of Climate-Related Disclosures for Investors; Proposed Rule, Securities and Exchange Commission; Money Market Fund Reforms; Proposed Rule, Securities and Exchange Commission; Share Repurchase Disclosure Modernization; Notice, Internal Revenue Service; Priority Guidance Plan; Compliance Assistance Release, Department of Labor; 401(k) Plan Investments in Cryptocurrencies Request for Information, Consumer Financial Protection Bureau; Fees Imposed by Providers of Consumer Financial Products or Services; cybersecurity risk management and incident reporting; enhancement and standardization of climate related disclosures to investors SEC regulation

Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Durbin Interchange Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2561, Promoting Access to Capital in Unbanked Communities Act of 2021 S. 910, SAFE Banking Act S.J.RES.15, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders." H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate LIBOR Act H.R. 5189, Member Business Loan Expansion Act S. 2508, Veterans and Consumer Fair Credit Act Perlmutter Amendment (H.Amdt.97) to H.R. 4350, National Defense Authorization Act of 2022 H.R. 2989, Financial Transparency Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024. Emergency Capital Investment Issues for CDFI and MDI S. 3715, The E-SIGN Modernization Act Coin Circulation S. 3779, Adjustable Interest Rate LIBOR Act H.R. 7351, To amend the Consumer Financial Protection Act of 2010 to provide for the supervision of non-depository persons offering or making small business loans, and for other purposes. H.R. 4277, Overdraft Protection Act of 2021 H.R 4521, America Competes Act of 2022 H.R.7003, Expanding Financial Access for Underserved Communities Act

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

H.R. 935, Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2021 H.R. 1087, Shareholder Political Transparency Act of 2021 H.R. 1187, Corporate Governance Improvement and Investor Protection Act H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 1602, Eliminate Barriers to Innovation Act of 2021 H.R. 2025/S. 840, To amend title 28, United States Code, to increase transparency and oversight of third-party litigation funding in certain actions, and for other purposes H.R. 2516, Promoting Diversity and Inclusion in Banking Act of 2021 H.R. 2543, Federal Reserve Racial and Economic Equity Act H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2570, Climate Risk Disclosure Act of 2021 H.R. 2620, Investor Choice Act of 2021 H.R. 3007, Disclosure of Tax Havens and Offshoring Act H.R. 3448, Helping Startups Continue to Grow Act H.R. 3454, Modernizing Disclosures for Investors Act H.R. 4277, Overdraft Protection Act of 2021 H.R. 4345, Financial Services and General Government Appropriations Act, 2022 H.R. 4350, National Defense Authorization Act for Fiscal Year 2022 H.R. 4521, America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength (America COMPETES) Act of 2022, including provisions related to House Amendment 218 H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate (LIBOR) Act of 2021 H.R. 4773, Consumer Financial Protection Commission Act H.R. 5586/S. 3056, Prohibiting IRS Financial Surveillance Act H.R. 5648/S. 3022, Stop Wall Street Looting Act H.R. 5910, Holding SPACs Accountable Act of 2021 H.R. 5911, Fair Hiring in Banking Act S. 479, Lifting Our Communities through Advance Liquidity for (LOCAL) Infrastructure Act S. 2417, Credit Access and Inclusion Act of 2021 S. 2508, Veterans and Consumers Fair Credit Act S. 2621, Modernization of Derivatives Tax Act of 2021 S. 3410, The Consumer Protection and Due Process Act S. 3755, Arbitration Fairness for Consumers Act S. 3844, Economic Continuity and Stability Act S. 3914, Developing and Empowering our Aspiring Leaders Act of 2022 Potential legislation to foster economic growth and job creation through capital formation Potential legislation to further economic growth through environmental, social, and governance factors Potential legislation to speed up the timeline of the Holding Foreign Companies Accountable Act Potential legislation to enshrine SEC threshold ownership requirements for shareholder proposals Potential legislation to require the SEC to study barriers in accessing capital for minority entrepreneurs Potential legislation to expressing a sense of Congress reaffirming the Supreme Court materiality standard Nomination of Sarah Bloom Raskin to Serve as Vice Chair for Supervision of the Federal Reserve Board of Governors Proposed rule regarding SEC Enhanced Reporting of Proxy Votes by Registered Management Investment Companies; Reporting of Executive Compensation Votes by Institutional Investment Managers Proposed Rule (86 Fed. Reg. 57,478-57,524, October 15, 2021) Proposed rule regarding SEC Reporting of Securities Loans (86 Fed. Reg. 69,802-69.853, December 8, 2021) Proposed rule regarding Position Reporting of Large Security-Based Swap Positions (87 Fed. Reg. 6,652-6,706, December 15, 2021) SEC Money Market Fund Reforms (86 Fed. Reg. 7,248, December 15, 2021) Proposed rules regarding amendments to Form PF (87 FR 9,106-9,235, January 26, 2022) Request for Information on "Review of Bank Secrecy Act Regulations and Guidance, Financial Crimes Enforcement Network (FinCEN); (86 Fed. Reg. 71,201-71,207, December 15, 2021) Reopening of Comment Period for Pay Versus Performance Proposed Rule, Securities and Exchange Commission; (87 Fed. Reg. 5,751-5,759, February 2, 2022) Request for Information Regarding Fees Imposed by Providers of Consumer Financial Products or Services, Consumer Financial Protection Bureau; (87 Fed. Reg. 5,801-5,803, February 2, 2022) Various issues relating to SEC Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; Public Company Accounting Oversight Board (PCAOB); CFTCs de minimis Exception for Swap Dealers; CFPB regulatory sandbox for disclosures; Securities and Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); qualified mortgage definition under the Truth in Lending Act (P.L. 90-321) (Regulation Z); Financial Stability Oversight Council and the designation of Nonbank Financial Firms as systemically important; Federal Reserve Systems Large Institution Supervision Coordinating Committee; potential housing finance reform legislation; enforcement of Securities and Exchange Commission penalties; potential repeal of the State and Local Tax (SALT) Cap; federal interest rate authority; Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) reform; electronic consent-based SSN Verification Service (eCBSV); environmental, social, and governance (ESG) enforcement; information Collection under the Community Reinvestment Act (CRA); potential Financial Transaction Tax (FTT); potential Treasury Department proposal relating to tax reporting by banks; investment company cross trading; potential money market fund reform measures; resolutions to establish task forces on Artificial Intelligence and Financial Technology in the House Committee on Financial Services; transition to the secured overnight financing rate; implementation of SEC Rule 15c2-11; Department of Labor fiduciary advice exemption: PTE 2020-02; benefits of risk-based pricing; mobile disclosures; Federal Trade Commission issues: Freedom of Information Act Requests, Penalty Offense Authority, Zombie Voting, and overall direction of the Commission under Chair Lina Khan; Tax Reporting Proposal by the Department of the Treasury related to a $600 or more annual account threshold; Amendment to the FY22 National Defense Authorization Act related to credit reporting; Climate-Related Financial Risk Management for Large Banks; House Committee on Financial Services request for information related to Russia sanctions; EU sustainable finance action plan and incorporating ESG factors into financial services; EU review of Alternative Investment Fund Managers Directive; EU review of prudential regime for investment firms; implementation and enforcement of Regulation Best Interest by the Securities and Exchange Commission; changes in the enforcement policies of the Securities and Exchange Commission; activity of the Financial Stability Oversight Council and recommendations on macro-prudential regulation; clarification in the regulatory treatment of digital assets by the Securities and Exchange Commission and the Commodity Futures Trading Commission; implementation and enforcement of SEC 14a-8 shareholder proposal process reforms finalized in 2020; EU Money Market Fund Regulation, legislative review; electronic delivery of certain investment documents and disclosures; implementation of beneficial ownership reporting requirements under the National Defense Authorization Act FY2021 (P.L. 116-283); implementation of the Social Security Administrations Electronic Consent Based Social Security Number Verification System Service; Financial Stability Board recommendations on money market fund reform; IOSCO recommendations on sustainability-related practices, polices, procedures, and disclosure in asset management; Office of Financial Research (OFR) discussions on FSOC Report on Climate-Related Financial Risk; staff legal guidance at the SEC concerning no-action letters on shareholder proposals with broad societal impact (Staff Legal Bulletin 14L-CF); SEC reforms to regulations related to climate disclosures; SEC reforms to regulations related to Shareholder Proposals; SEC reforms to regulations related to Cybersecurity Disclosures; SEC reforms to regulations related to Human Capital Management Disclosures; SEC reforms to regulations related to Share Repurchase Disclosures; SEC reforms to regulations related to 10b5-1 Disclosure; SEC request for information on digital engagement practices; FinCEN Implementation of the Beneficial Ownership Requirements of the Corporate Transparency Act; SEC Reopening of Comment Period on Pay Versus Performance; SEC Proposed Rule Regarding Share Repurchase Disclosure Modernization; SEC Proposed Rule amending 10b5-1; Proposed Rule, Securities and Exchange Commission; Prohibition Against Fraud, Manipulation, or Deception in Connection with Security-Based Swaps, Prohibition against Undue Influence over Chief Compliance Officers, Position Reporting of Large Security-Based Swap Positions; Proposed Rule, Securities and Exchange Commission; Rule 10b5-1 and Insider Trading; Proposed Rule, Securities and Exchange Commission; Share Repurchase Disclosure Modernization; Proposed Rule, Securities and Exchange Commission; Proxy Voting Advice; Requesting an Extension of the Comment Period for the Securities and Exchange Commissions Private Fund Advisers Proposal; Proposed rule, Securities and Exchange Commission; Reporting of Securities Loans; third party litigation financing and lawsuit lending; cybersecurity risk management and incident reporting; enhancement and standardization of climate related disclosures to investors SEC 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 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.

H.R. 935, Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2021 H.R. 1087, Shareholder Political Transparency Act of 2021 H.R. 1187, Corporate Governance Improvement and Investor Protection Act H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 1602, Eliminate Barriers to Innovation Act of 2021 H.R. 2025/S. 840, To amend title 28, United States Code, to increase transparency and oversight of third-party litigation funding in certain actions, and for other purposes H.R. 2072, Uyghur Forced Labor Disclosure Act H.R. 2516, Promoting Diversity and Inclusion in Banking Act of 2021 H.R. 2543, Federal Reserve Racial and Economic Equity Act H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2570, Climate Risk Disclosure Act of 2021 H.R. 2620, Investor Choice Act of 2021 H.R. 3007, Disclosure of Tax Havens and Offshoring Act H.R. 3448, Helping Startups Continue to Grow Act H.R. 3454, Modernizing Disclosures for Investors Act H.R. 4277, Overdraft Protection Act of 2021 H.R. 4345, Financial Services and General Government Appropriations Act, 2022 H.R. 4350, National Defense Authorization Act for Fiscal Year 2022 H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate (LIBOR) Act of 2021 H.R. 4773, Consumer Financial Protection Commission Act H.R. 5586/S. 3056, Prohibiting IRS Financial Surveillance Act H.R. 5648/S. 3022, Stop Wall Street Looting Act H.R. 5910, Holding SPACs Accountable Act of 2021 H.R. 5911, Fair Hiring in Banking Act S. 479, Lifting Our Communities through Advance Liquidity for (LOCAL) Infrastructure Act S. 2417, Credit Access and Inclusion Act of 2021 S. 2508, Veterans and Consumers Fair Credit Act S. 2621, Modernization of Derivatives Tax Act of 2021 S. 3410, The Consumer Protection and Due Process Act Potential legislation to foster economic growth and job creation through capital formation Potential legislation to further economic growth through environmental, social, and governance factors Potential legislation to speed up the timeline of the Holding Foreign Companies Accountable Act Potential legislation to enshrine SEC threshold ownership requirements for shareholder proposals Potential legislation to require the SEC to study barriers in accessing capital for minority entrepreneurs Potential companion legislation to H.R. 4616, Adjustable Interest Rate (LIBOR) Act of 2021 Nomination of Saule Omarova to serve as Comptroller of Currency Proposed rule regarding SEC Proxy Voting Advice Proposed Rule (86 Fed. Reg. 67,383-67,402, November 26, 2021) Proposed rule regarding SEC Enhanced Reporting of Proxy Votes by Registered Management Investment Companies; Reporting of Executive Compensation Votes by Institutional Investment Managers Proposed Rule (86 Fed. Reg. 57,478-57,524, October 15, 2021) Notice, Federal Reserve System, the Federal Deposit Insurance Corporation, and the Comptroller of the Currency; Proposed Interagency Guidance on Third-Party Relationships: Risk Management, (86 Fed. Reg. 38,182-38,204, July 19, 2021) Final rule regarding SEC Universal Proxy (86 Fed. Reg. 68,330-68,381, December 1, 2021) Various issues relating to SEC Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; Public Company Accounting Oversight Board (PCAOB); CFTCs de minimis Exception for Swap Dealers; CFPB regulatory sandbox for disclosures; Securities and Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); qualified mortgage definition under the Truth in Lending Act (P.L. 90-321) Regulation Z; Financial Stability Oversight Council and the designation of Nonbank Financial Firms as systemically important; Federal Reserve Systems Large Institution Supervision Coordinating Committee; potential housing finance reform legislation; enforcement of Securities and Exchange Commission penalties; potential repeal of the State and Local Tax (SALT) Cap; federal interest rate authority; Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) reform; electronic consent-based SSN Verification Service (eCBSV); environmental, social, and governance (ESG) enforcement; information Collection under the Community Reinvestment Act (CRA); potential Financial Transaction Tax (FTT); potential Treasury Department proposal relating to tax reporting by banks; investment company cross trading; potential money market fund reform measures; resolutions to establish task forces on Artificial Intelligence and Financial Technology in the House Committee on Financial Services; transition to the secured overnight financing rate; implementation of SEC Rule 15c2-11; Department of Labor fiduciary advice exemption: PTE 2020-02; benefits of risk-based pricing; mobile disclosures; Federal Trade Commission issues: Freedom of Information Act Requests, Penalty Offense Authority, Zombie Voting, and overall direction of the Commission under Chair Lina Khan; Tax Reporting Proposal by the Department of the Treasury related to a $600 or more annual account threshold; Amendment to the FY22 National Defense Authorization Act related to credit reporting; EU sustainable finance action plan and incorporating ESG factors into financial services; EU review of Alternative Investment Fund Managers Directive; EU review of prudential regime for investment firms; implementation and enforcement of Regulation Best Interest by the Securities and Exchange Commission; changes in the enforcement policies of the Securities and Exchange Commission; activity of the Financial Stability Oversight Council and recommendations on macro-prudential regulation; clarification in the regulatory treatment of digital assets by the Securities and Exchange Commission and the Commodity Futures Trading Commission; implementation and enforcement of proxy advisory firm regulations finalized in 2020; implementation and enforcement of SEC 14a-8 shareholder proposal process reforms finalized in 2020; EU Money Market Fund Regulation, legislative review; electronic delivery of certain investment documents and disclosures; implementation of beneficial ownership reporting requirements under the National Defense Authorization Act FY2021 (P.L. 116-283); implementation of the Social Security Administrations Electronic Consent Based Social Security Number Verification System Service; Financial Stability Board recommendations on money market fund reform; IOSCO recommendations on sustainability-related practices, polices, procedures, and disclosure in asset management; Office of Financial Research (OFR) discussions on FSOC Report on Climate-Related Financial Risk; staff legal guidance at the SEC concerning no-action letters on shareholder proposals with broad societal impact (Staff Legal Bulletin 14L-CF); SEC request for information on climate disclosures; SEC Reforms to regulations related to Shareholder Proposals; SEC Reforms to regulations related to Cybersecurity Disclosures; SEC Reforms to regulations related to Human Capital Management Disclosures; SEC Reforms to Money Market Funds Regulations; SEC request for information on digital engagement practices; FinCEN Implementation of the Beneficial Ownership Requirements of the Corporate Transparency Act; potential legislation dealing with third party litigation financing and lawsuit lending

H.R. 1187 Corporate Governance Improvement and Investor Protection Act (climate provisions) H.R. 1319 American Rescue Plan Act of 2021 H.R. 1711 Financial Inclusion in Banking Act of 2021 H.R. 1996 SAFE Banking Act H.R. 2211 Central Bank Digital Currency Study Act H.R. 2561 Promoting Access to Capital in Underbanked Communities Act of 2021 H.R. 2570 Climate Risk Disclosure Act of 2021 H.R. 3009 Improving Language Access in Mortgage Servicing H.R. 3910 To Amend the Gramm Leach Bliley Act to give the CFPB rulemaking and enforcement authority over the safeguards rule with respect to data aggregators H.R. 3926 Securing and Enabling Commerce Using Remote and Electronic Notarization Act of 2021 H.R. 4277 Overdraft Protection Act H.R. 4345 FY 2022 Financial Services and General Government Appropriation - Postal Banking Pilot Program H.R. 4350 National Defense Authorization Act for FY 2022 cybersecurity provisions H.R. 4590 The Promoting New and Diverse Depository Institutions Act H.R. 4616 The Adjustable Interest Rate (LIBOR) Act H.R. 4773 The Consumer Financial Protection Commission Act H.R. 5253 Fossil Free Finance Act H.R. 5376 The Build Back Better Act H.R. 5440 Cyber Incident Reporting for Critical Infrastructure Act H.R. 5874 Veterans and Consumers Fair Credit Act H.R. 5886 Prohibit IRS Financial Surveillance Act H.R. 5911 Fair Hiring in Banking Act H.R. 5974 Veterans and Consumers Fair Credit Act H.R. 6037 Prohibit SBA 7(a) Direct Lending H.R. 6145 Community Bank Relief Act H.R. 6307 Protecting Access to Credit for Small Businesses Act S. 910 SAFE Banking Act S. 1625 Securing and Enabling Commerce Using Remote and Electronic Notarization Act of 2021 S. 2407 Cyber Incident Notification Act of 2021 S. 2508 Veterans and Consumers Fair Credit Act S. 2792 National Defense Authorization Act for FY2022 S. 2857 Protecting Financial Privacy Act S. 2875 Cyber Incident Reporting Act of 2021 S. 3056 Prohibit IRS Financial Surveillance Act S. 3382 Protecting Access to Credit for Small Businesses Act S. 3409 A bill to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024, and for other purposes. S. Amend 3099 - Amendment to the Senate Budget Resolution to bar new IRS reporting Audit and reporting regulatory asset thresholds Bank Capital and Accounting Relief Bank Secrecy Act/Anti-Money Laundering Rules/Legislation, including Beneficial Ownership Issue Cannabis Banking CARES Act, Paycheck Protection Program Implementation Central Bank Digital Currency Climate-Related Financial Regulation Community Bank Access to Capital Community Bank Leverage Ratio Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Modernization Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Supplemental Capital Cryptocurrency Current Expected Credit Loss Standard Customer Data Access, Implementation of Dodd Frank Act Section 1033 Cyber Incident reporting legislation Cybersecurity Data Security, Breaches and Privacy De Novo Bank Formation DFA 1071- Small Business Loan Data Collection Durbin Amendment on Interchange; Extension to Credit Cards Enhancing Cybersecurity of Nationwide Consumer Reporting Agencies Act (draft) Equal treatment between community banks and credit unions when assessing rent and related charges on military bases. Expanding Employment Opportunities in Banking - Criminal History Disclosures Faster/Instant Payments Federal Reserve Accounts for Consumers Fintech Regulatory Requirements Fintech/Banking Relationships Flood Insurance Reauthorization Industrial Loan Corporation Loophole Reforms/ Rakuten (ILC) et al, Deposit Insurance Applications Interchange Interest Rate Caps IRS Reporting of Financial Account Inflows/Outflows LIBOR Transition Minority Depository Institutions Issues Nomination of Professor Saule Omarova for Comptroller of the Currency OCC Proposed Payments Charter Overdraft Fees Overdraft Protection Payment semi-conductor chip disruptions Postal Banking Protecting Financial Privacy Act introduced in the Senate and the House Public Banking Raising the FDICIA Asset Thresholds of 12 CFR Part 363--FDIC Regulatory and Tax Relief for Community Banks SBA 7(a) Loan Program Funding and Terms SBA Direct 7(a) Direct Lending Simplification of Deposit Insurance Rules Small Business Loan Data Collection--CFPB Implementation of Dodd-Frank Act Section 1071 Stablecoins Supervisory Approaches (On-Site/Off-Site) Examinations Tailored Supervision of Community Banks (draft legislation) The Strengthening Cybersecurity for the Financial Sector Act (draft legislation)

Bank On Buy Now, Pay Later Central Bank Digital Currency Cryptocurrency Durbin Interchange Nominations USPS Pilot Banking Program H.R. 1996, The SAFE Banking Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2561, Promoting Access to Capital in Unbanked Communities Act of 2021 S. 910, SAFE Banking Act S.J.RES.15, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders." H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate LIBOR Act H.R. 5189, Member Business Loan Expansion Act S. 2508, Veterans and Consumer Fair Credit Act Perlmutter Amendment (H.Amdt.97) to H.R. 4350, National Defense Authorization Act of 2022 H.R. 2989, Financial Transparency Act H.R. 6145, Community Bank Relief Act of 2021 S. 3409, To amend the Economic Growth, Regulatory Relief, and Consumer Protection Act to require the appropriate Federal banking agencies to develop a Community Bank Leverage Ratio that is between 8 percent and 8.5 percent for calendar years 2022, 2023, and 2024.

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

H.R.2561 - Promoting Access to Capital in Underbanked Communities Act of 2021 Section 3. Phase-In Of Capital Standards Section 4. Changes To Business Plan Section 5. Rural Bank Community Leverage Ratio H.R.4590 - Promoting New and Diverse Depository Institutions Act Section 2. Study and Strategic Plan

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 935, Small Business Mergers, Acquisitions, Sales, and Brokerage Simplification Act of 2021 H.R. 1087, Shareholder Political Transparency Act of 2021 H.R. 1187, Corporate Governance Improvement and Investor Protection Act H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 1602, Eliminate Barriers to Innovation Act of 2021 H.R. 2025/S. 840, To amend title 28, United States Code, to increase transparency and oversight of third-party litigation funding in certain actions, and for other purposes H.R. 2516, Promoting Diversity and Inclusion in Banking Act of 2021 H.R. 2543, Federal Reserve Racial and Economic Equity Act H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2570, Climate Risk Disclosure Act of 2021 H.R. 3007, Disclosure of Tax Havens and Offshoring Act H.R. 3412, Alleviating Stress Test Burdens to Help Investors Act H.R. 3448, Helping Startups Continue to Grow Act H.R. 3454, Modernizing Disclosures for Investors Act H.R. 4345, Financial Services and General Government Appropriations Act, 2022 H.R. 4350, National Defense Authorization Act for Fiscal Year 2022 H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate (LIBOR) Act of 2021 H.R. 4773, Consumer Financial Protection Commission Act S. 479, Lifting Our Communities through Advance Liquidity for (LOCAL) Infrastructure Act S. 2417, Credit Access and Inclusion Act of 2021 S. 2508, Veterans and Consumers Fair Credit Act S.J. Res. 15, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders" Potential legislation to foster economic growth and job creation through capital formation Nomination of Saule Omarova to serve as Comptroller of Currency Request for Information on Monitoring Availability and Affordability of Auto Insurance; Assessing the Potential Evolution of the Auto Insurance Market (86 Fed. Reg. 28,681 - 28,683, May 27, 2021) Request for Comment, Agency Information Collection Activities (86 Fed. Reg. 43,999 - 44,000, August 11, 2021) Various issues relating to SEC Best Interest and Enhancing Investment Adviser Regulation relating to broker-dealers, registered investment advisers, conflicts of interest; potential federal preemption of state fiduciary standards; Public Company Accounting Oversight Board (PCAOB); CFTCs de minimis Exception for Swap Dealers; CFPB regulatory sandbox for disclosures; Securities and Exchange Commission amendments to the Commissioners whistleblower rules file no. S7-16-18; proxy process, proxy advisory firms, and other related aspects of corporate governance; corporate common ownership; adoption of the current expected credit loss (CECL) accounting standard; role of credit reporting agencies (CRAs) in the U.S. economy; debt collection practices (regulation F) under the Fair Debt Collection Practices Act (P.L. 95-109); qualified mortgage definition under the Truth in Lending Act (P.L. 90-321) Regulation Z; Financial Stability Oversight Council and the designation of Nonbank Financial Firms as systemically important; Federal Reserve Systems Large Institution Supervision Coordinating Committee; potential housing finance reform legislation; enforcement of Securities and Exchange Commission penalties; potential repeal of the State and Local Tax (SALT) Cap; federal interest rate authority; Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) reform; electronic consent-based SSN Verification Service (eCBSV); environmental, social, and governance (ESG) enforcement; information Collection under the Community Reinvestment Act (CRA); potential Financial Transaction Tax (FTT); potential Treasury Department proposal relating to tax reporting by banks; investment company cross trading; potential money market fund reform measures; resolutions to establish task forces on Artificial Intelligence and Financial Technology in the House Committee on Financial Services; transition to the secured overnight financing rate; implementation of SEC Rule 15c2-11; Department of Labor fiduciary advice exemption: PTE 2020-02; benefits of risk-based pricing; SEC request for information on climate disclosures; SEC Reforms to regulations related to Proxy Advice; SEC Reforms to regulations related to Proxy Voting; SEC Reforms to regulations related to Shareholder Proposals; SEC Reforms to Money Market Funds Regulations; SEC implementation of Rule 15c2-11; SEC request for information on digital engagement practices; FinCEN Implementation of the Beneficial Ownership Requirements of the Corporate Transparency Act; EU sustainable finance action plan and incorporating ESG factors into financial services; EU review of Alternative Investment Fund Managers Directive; EU review of prudential regime for investment firms; implementation and enforcement of Regulation Best Interest by the Securities and Exchange Commission; changes in the enforcement policies of the Securities and Exchange Commission; activity of the Financial Stability Oversight Council and recommendations on macro-prudential regulation; clarification in the regulatory treatment of digital assets by the Securities and Exchange Commission and the Commodity Futures Trading Commission; implementation and enforcement of proxy advisory firm regulations finalized in 2020; implementation and enforcement of SEC 14a-8 shareholder proposal process reforms finalized in 2020; EU Money Market Fund Regulation, legislative review; electronic delivery of certain investment documents and disclosures; implementation of beneficial ownership reporting requirements under the National Defense Authorization Act FY 2021 (P.L. 116-283); implementation of the Social Security Administrations Electronic Consent Based Social Security Number Verification System Service; Financial Stability Board recommendations on money market fund reform; IOSCO recommendations on sustainability-related practices, polices, procedures, and disclosure in asset management; Office of Financial Research (OFR) discussions on FSOC Report on Climate-Related Financial Risk; potential legislation dealing with third party litigation financing and lawsuit lending

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.

Bank On Central Bank Digital Currency Cryptocurrency Durbin Interchange Nominations H.R. 1996, The SAFE Banking Act H.R. 1319, American Rescue Plan Act of 2021 H.R. 1277/S. 374, Improving Corporate Governance Through Diversity Act of 2021 H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 2561, Promoting Access to Capital in Unbanked Communities Act of 2021 S. 910, SAFE Banking Act S.J.RES.15, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of the Comptroller of Currency relating to "National Banks and Federal Savings Associations as Lenders". H.R. 4590, Promoting New and Diverse Depository Institutions Act H.R. 4616, Adjustable Interest Rate LIBOR Act H.R. 5189, Member Business Loan Expansion Act S. 2508, Veterans and Consumer Fair Credit Act Perlmutter Amendment (H.Amdt.97) to H.R. 4350, National Defense Authorization Act of 2022 H.R. 2989, Financial Transparency Act

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

H.R. 1187 Corporate Governance Improvement and Investor Protection Act (climate provisions) H.R. 1319 American Rescue Plan Act of 2021 H.R. 1711 Financial Inclusion in Banking Act of 2021 H.R. 1799 The PPP Extension Act H.R. 1996 SAFE Banking Act H.R. 2211 Central Bank Digital Currency Study Act H.R. 2547 Comprehensive Debt Collection Improvement Act H.R. 2561 Promoting Access to Capital in Underbanked Communities Act of 2021 H.R. 2570 Climate Risk Disclosure Act of 2021 H.R. 3009 Improving Language Access in Mortgage Servicing H.R. 3910 To Amend the Gramm Leach Bliley Act to give the CFPB rulemaking and enforcement authority over the safeguards rule with respect to data aggregators H.R. 3911 To Amend the GLBA to establish procedures for disclosures by financial institutions of nonpublic personal information H.R. 3912 To amend the GBLA to require consumers to opt in before a financial institution may share the nonpublic personal information H.R. 3926 Securing and Enabling Commerce Using Remote and Electronic Notarization Act of 2021 H.R. 4345 FY 2022 Financial Services and General Government Appropriation - Postal Banking Pilot Program H.R. 4350 National Defense Authorization Act for FY 2022 cybersecurity provisions H.R. 4590 The Promoting New and Diverse Depository Institutions Act H.R. 4616 The Adjustable Interest Rate (LIBOR) Act H.R. 4773 The Consumer Financial Protection Commission Act H.R. 5253 Fossil Free Finance Act H.R. 5376 The Build Back Better Act H.R. 5440 Cyber Incident Reporting for Critical Infrastructure Act H.J. Res. 25 Congressional disapproval of OCC True Lender Rule S. 910 SAFE Banking Act S. 1625 Securing and Enabling Commerce Using Remote and Electronic Notarization Act of 2021 S. 2407 Cyber Incident Notification Act of 2021 S. 2508 Veterans and Consumers Fair Credit Act S. 2792 National Defense Authorization Act for FY2022 S. 2816 PIGGY BANK Act S. 2857 - Protecting Financial Privacy Act S. 2875 Cyber Incident Reporting Act of 2021 S. Amend 3099 - Amendment to the Senate Budget Resolution to bar new IRS reporting S.J. Res. 15 Congressional disapproval of OCC True Lender Rule Audit and reporting regulatory asset thresholds Bank Capital and Accounting Relief Bank Secrecy Act/Anti-Money Laundering Rules/Legislation, including Beneficial Ownership Issue Brokered Deposits Cannabis Banking CARES Act, Economic Impact Payments CARES Act, Paycheck Protection Program Implementation Central Bank Digital Currency/Digital Dollar Climate Crisis Financial Stability Act (draft) Climate Crisis Financial Stability Act (draft) Climate-Related Financial Regulation Community Bank Access to Capital Community Bank Leverage Ratio Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Modernization Credit Reporting Credit Union Acquisitions of Community Banks/Vystar CU-Heritage Southeast Bank Transaction and Wings Financial CU/Brainerd Savings and Loan Transaction Credit Union Business Lending Powers Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Supplemental Capital Cryptocurrency Customer Data Access, Implementation of Dodd Frank Act Section 1033 Cyber Incident reporting legislation Cybersecurity Data Security, Breaches and Privacy De Novo Bank Formation DFA 1071- Small Business Loan Data Collection Durbin Amendment on Interchange; Extension to Credit Cards Emergency Capital Investment Program Implementation Equal treatment between community banks and credit unions when assessing rent and related charges on military bases. Federal Reserve Accounts for Consumers Fintech Regulatory Requirements Fintech/Banking Relationships Flood Insurance Reauthorization House - The Public Banking Act of 2021 (draft) House - The Access to No-Fee Accounts Act of 2021 (draft) Industrial Loan Corporation Loophole Reforms/ Rakuten (ILC) et al, Deposit Insurance Applications Interchange Interest Rate Caps IRS Reporting Issue LIBOR Transition Minority Depository Institutions Issues OCC Interpretive Letter 1176/Protego & Anchorage Conversion Applications OCC Proposed Payments Charter Postal Banking Protecting Financial Privacy Act introduced in the Senate and the House Public banking Raising the FDICIA asset thresholds of Part 363--FDIC Regulatory and Tax Relief for Community Banks SBA 7(a) Loan Program Funding and Terms Small Business Loan Data Collection--CFPB Implementation of Dodd-Frank Act Section 1071 Stablecoins