To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program, and for other purposes.

3/8 Senate Banking Hearing: Examining Mandatory Arbitration in Financial Service Products H.R. 963 Forced Arbitration Injustice Repeal (FAIR) Act of 2022 3/31 House Financial Services Subcommittee on Consumer Protection and Financial Institutions Hearing- The End of Overdraft Fees? Examining the Movement to Eliminate the Fees Costing Consumers Billions House/Senate Hearing: Annual Oversight of the Nations Largest Banks S.4674 - Credit Card Competition Act of 2022 H.R.8874 - Credit Card Competition Act of 2022 Issues related to Zelle payment platform and changes to Regulation E House Financial Services Discussion Draft: Stable Coin Legislation Issues related to Biden Administration Student Loan Forgiveness Plan Issues related to changing UDAAP legislation Issues related to banning arbitration agreements H.R.7900 - National Defense Authorization Act for Fiscal Year 2023 H.R. 8152 - American Data Privacy and Protection Act H.R. ____ - Protecting Consumers From Payment Scams Act Issues related to Section 1034 of Dodd-Frank Act Issues related to CFPB Credit Card Late Fees and Late Payments H.R.7412 - Transparency in CFPB Cost-Benefit Analysis Act H.R.6802 - Preventing Racial Profiling in Lending Act H.R.6732 - Small LENDER Act H.R.7352 - PPP and Bank Fraud Enforcement Harmonization Act of 2022 Issues related to 7/29 Senate Banking Hearing - Extending the Military's 36% Interest Rate Cap to Everyone Draft Legislation - Access to No-Fee Accounts Act. Pub. Law 117-169 Build Back Better Act - Implementation of IRS Reporting Bank Account Information H.R.4277 - Overdraft Protection Act of 2021 Issues related to By Now/Pay Later Financial Products Issues related to SBA Direct 7(a) lending program H.R. 6037, To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program, and for other purposes. S. 3382, To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program. Issues related to transition from LIBOR Rate S. 3056, the Prohibiting IRS Financial Surveillance Act Issues related to FDIC Director appointment House/Senate Semi-annual Hearing with the Director of the CFPB Issues related to Cyber Security, Data Security & Breach Notification Issues related to Consumer Data Privacy Issues related to the Community Reinvestment Act Issues related to fair lending and fair banking Issues related to CFPB supervisory authority under Section 1024 Issues related to Dodd-Frank including Section 1033 Issues related to the Consumer Financial Protection Bureau H.R. 4773, the Consumer Financial Protection Commission Act Legislation related to establishing a commission at the CFPB Issues related to Interest Rate Caps on Banks Issues related to CFPB Consumer Response Portal Issues related to CFPB Taskforce on Consumer Financial Laws CFPB Section 1071 rulemaking Issues related to Underbanked/Unbanked Consumers Issues related to CFPB agency guidance Issues related to bank fees, including overdraft fees and credit card late fees. Issues related to COVID-19 pandemic H.R. 4120, To amend the Fair Credit Reporting Act to provide comprehensive reforms to the consumer credit reporting laws, and for other purposes H.R. 4277, To amend the Truth in Lending Act to establish fair and transparent practices related to the marketing and provision of overdraft coverage programs at financial institutions, and for other purposes Issues related to credit card network interchange fees. Issues related to U.S. Postal Service banking services. Issues related to the Federal Reserve Central Digital Bank Currency Issues related to the Federal Reserve Consumer checking accounts H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 Issues related to the reauthorization of the Higher Education Act Issues related to the CFPBs and Department of Educations actions on student lending Issues related to disclosures for federal student loans Legislation related to student loan refinancing programs Issues related to bankruptcy protections for student loans Issues related to federal student loan reform H.R. 2498, Private Loan Disability Discharge Act of 2021 Issues related to AML-BSA Reform Issues related to FinCEN CDD Rule Issues related to Appropriations H.R. 4345, Financial Services and General Government Appropriations Act, 2022 H.R. 4350/S. 2792, National Defense Authorization Act for Fiscal Year 2022 S. Con. Res. 14, A concurrent resolution setting forth the congressional budget for the United States Government for fiscal year 2022 and setting forth the appropriate budgetary levels for fiscal years 2023 through 2031 Issues related to the Fair Credit Reporting Act H.R. 3642 (116th Cong.), Improving Credit Reporting for All Consumers Act H.R. 953 (116th Cong.), To prohibit consumer reporting agencies from including adverse information in certain consumer reports, and from making adverse determinations relating to security clearances, with respect to certain individuals affected by the Government shutdown, and for other purposes. H.R. 1500 (116th Cong.), Consumers First Act Issues related to the Comprehensive Consumer Credit Reporting Reform Act of 2019 H.R. 4120, Comprehensive Credit Reporting Enhancement, Disclosure, Innovation, and Transparency Act of 2021 Draft Legislation - Protecting Your Credit Score Act of 2021 Issues related to the Community Reinvestment Act Issues related to financial regulatory coordination Issues related to SBA 7(a) Loan Program and fees H.R. 5050 (116th Cong.), the Veterans and Consumers Fair Credit Act Issues related to the Fair Housing Act Issues related to FinTech Issues related to the E-SIGN Act Issues related to the Bank Secrecy Act and Anti-Money Laundering Issues related to the Counter Terrorism & Illicit Finance Act S. 2563 (116th Cong.), the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act Issues related to Parent Companies of Industrial Banks and Industrial Loan Companies Regulations: Equal Credit Opportunity issues, Regulation B, 12 CFR Part 1002 Home Mortgage Disclosure Act Issues, Regulation C, 12 CFR Part 1003 Fair Debt Collection Practices Issues, Regulation F, 12 CFR Part 1006 Privacy Issues, 12 CFR Parts 40, 216, 332, 1016 Fair Credit Reporting Issues, 12 CFR Parts 41, 171, 334, 1022 Truth in Lending Issues, Regulation Z, 12 CFR Part 1026 Regulations related to the Dodd-Frank Act, Pub. L. No. 111-203 Issues related to the Higher Education Act Issues related to Electronic Fund Transfer Act, regulation E, 15 U.S.C. 1693 Issues related to FDIC Deposit Insurance Issues related to the Paperwork Reduction Act Issues related to the Military Lending Act Community Reinvestment Act Regulations & Q&A issues Issues related to the Servicemembers Civil Relief Act Issues related to Small Business Act Issues related to the Bank Secrecy Act and Anti-Money Laundering rules Issues related to Section 1033 of Dodd-Frank Issues related to Overdraft and non-sufficient funds (NSF) fees Issues related to Fintech oversight Issues related to Buy Now Pay Later Issues related to CFPB Credit Card Safe Harbor fee Issues related to Section 1071 Small Business Data Collection Issues related to UDAAP exam manual changes

Client expense: $1,290,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Education, Dept of, Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of

H.R. 6037/S. 3382, To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program, and for other purposes. H.R. 6054, Small Business Lending Disclosure Act of 2021 P.L. 116-260, Consolidated Appropriations Act, 2021, Treatment of Economic Injury Disaster Loans (EIDL); specifically, the covenants required by the Small Business Administration (SBA) 1071 Rulemaking; CFPB-2021-0015; impact on secured finance, particularly around trade credit

Client expense: Not reported · Firm income: $10,000

Government targets: Consumer Financial Protection Bureau (CFPB), HOUSE OF REPRESENTATIVES, SENATE

Paycheck Protection Program H.R. 1799 / S. 723, PPP Extension Act H.R. 6037, To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program. H.R. 6054, Small Business Lending Disclosure Act

Client expense: $2,840,000 · Firm income: Not reported

H.R. 6037 Prohibit SBA 7(a) Direct Lending H.R. 6307 Protecting Access to Credit for Small Business Act H.R. 7768 Farm Credit Administration Independence Authority Act S. 3382 Protecting Access to Credit for Small Business Act Opposing the SBAs proposal to repeal the moratorium on the number of Small Business Lending Companies (SBLC) that are permitted to make 7(a) loans. PPP Forgiveness Process SBA 7(a) Program Funding and Terms SBA COVID-19 Lending Programs SBA Direct Lending

Client expense: $1,303,790 · Firm income: Not reported

H.R. 1996 SAFE Banking Act H.R. 2543 Federal Reserve Racial and Economic Equity Act, Credit Union Provisions & Community Bank Amendment H.R. 2561 Promoting Access to Capital in Underbanked Communities Act of 2021 H.R. 2617 Consolidated Appropriations Act, opposed amendments related to Credit Card Competition Act H.R. 4277 Overdraft Protection Act H.R. 4345 FY 2022 Financial Services and General Government Appropriation - Postal Banking Pilot Program H.R. 5886 Prohibit IRS Financial Surveillance Act H.R. 5912 Close ILC Loophole Act H.R. 6037 Prohibit SBA 7(a) Direct Lending H.R. 6054 Small Business Lending Disclosure Act H.R. 6732 Small LENDER Act H.R. 6814 Small Business Fair Debt Collection Practices Act H.R. 7003 Expanding Financial Access for Underserved Communities Act H.R. 7412 Transparency in CFPB Cost-Benefit Analysis Act H.R. 7768 Farm Credit Administration Independence Authority Act H.R. 7776 National Defense Authorization Act, master accounts and services database H.R. 7900 National Defense Authorization Act, opposed amendments related to Credit Card Competition Act H.R. 8152 American Data Privacy and Protection Act H.R. 8443 Making the CFPB Accountable Act H.R. 8833 The Making Communities Stronger Through the Community Reinvestment Act H.R. 8874 Credit Card Competition Act H.R. 8950 the Digital Commodities Consumer Protection Act of 2022 H.R. 9599 Consumer Information Notification Requirement Act S. 910 SAFE Banking Act S. 1684 Federal Home Loan Banks Mission Implementation Act S. 3056 Prohibit IRS Financial Surveillance Act S. 3715 E-Sign Modernization Act S. 3954 Ban CBDC S. 3970 Stablecoin Transparency Act S. 4004 Small LENDER Act S. 4356 Lummis-Gillibrand Responsible Financial Innovation Act S. 4522 Transparency in CFPB Cost-Benefit Analysis Act S. 4674 Credit Card Competition Act S. 4698 Improving Cybersecurity of Credit Unions Act S. 4831 No CBDC Act S. 5189 Close the Shadow Banking Loophole Act S. 5340 Stablecoin TRUST Act of 2022 S. 5341 A bill to amend the Federal Reserve Act to provide greater accountability to the Federal Reserve System Bank Merger Policy BankOn accounts Banking Services Fees Cannabis Banking CDFI Certification Central Bank Digital Currency Climate Risk Disclosure Requirements Climate-Related Financial Regulation Community Bank Access to Capital Community Banks on Military Bases Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Consolidated Appropriations Act, supported inclusion of the SAFE Banking Act; opposed inclusion of Credit Card Competition Act Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Cybersecurity Requirements Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Supplemental Capital Cryptocurrency Customer Data Access, Implementation of Dodd Frank Act Section 1033 Cybersecurity Data Privacy Discussion Draft Data Security, Breaches and Privacy De Novo Bank Formation Dodd Frank Act 1071- Small Business Loan Data Collection Digital Assets Regulation Durbin Amendment on Interchange; Extension to Credit Cards FDIC Deposit Insurance Assessments FDIC Premium Increases FDIC Supervisory Appeals Review Committee and Policy FHFA Capital Rules Financial Data Privacy Discussion Draft Fintech Regulatory Requirements Fintech/Banking Relationships Flood Insurance Reauthorization Industrial Loan Corporation Loophole Reforms/ Rakuten (ILC) et al, Deposit Insurance Applications Interchange Minority Depository Institutions Issues National Defense Authorization Act, Report Language on Financial Institution leases on military bases National Defense Authorization Act, Supported Inclusion of the SAFE Banking Act; Opposed Inclusion of Credit Card Competition Act as an Amendment Overdraft Fees Overdraft Protection P2P Payment Applications Fraud Postal Banking SAFE Banking Act, support for inclusion in America COMPETES Act Conference SBA 7(a) Loan Program Funding and Terms SBA Direct 7(a) Direct Lending Secure Notarization Small Business Loan Data Collection--CFPB Implementation of Dodd-Frank Act Section 1071 Stablecoins Stablecoin Innovation and Protection Act of 2022 (draft) Stablecoin Legislation - Waters-McHenry Discussion Draft Stablecoin TRUST Act (draft)

H.R. 6037 Prohibit SBA 7(a) Direct Lending H.R. 6307 Protecting Access to Credit for Small Business Act H.R. 7768 Farm Credit Administration Independence Authority Act S. 3382 Protecting Access to Credit for Small Business Act PPP Forgiveness Process SBA 7(a) Program Funding and Terms SBA COVID-19 Lending Programs SBA Direct Lending

Client expense: $718,825 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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)

3/8 Senate Banking Hearing: Examining Mandatory Arbitration in Financial Service Products H.R. 963 Forced Arbitration Injustice Repeal (FAIR) Act of 2022 3/31 House Financial Services Subcommittee on Consumer Protection and Financial Institutions Hearing- The End of Overdraft Fees? Examining the Movement to Eliminate the Fees Costing Consumers Billions House/Senate Hearing: Annual Oversight of the Nations Largest Banks S.4674 - Credit Card Competition Act of 2022 H.R.8874 - Credit Card Competition Act of 2022 Issues related to Zelle payment platform and changes to Regulation E House Financial Services Discussion Draft: Stable Coin Legislation Issues related to Biden Administration Student Loan Forgiveness Plan Issues related to changing UDAAP legislation Issues related to banning arbitration agreements H.R.7900 - National Defense Authorization Act for Fiscal Year 2023 H.R. 8152 - American Data Privacy and Protection Act H.R. ____ - Protecting Consumers From Payment Scams Act Issues related to Section 1034 of Dodd-Frank Act Issues related to CFPB Credit Card Late Fees and Late Payments H.R.7412 - Transparency in CFPB Cost-Benefit Analysis Act H.R.6802 - Preventing Racial Profiling in Lending Act H.R.6732 - Small LENDER Act H.R.7352 - PPP and Bank Fraud Enforcement Harmonization Act of 2022 Issues related to 7/29 Senate Banking Hearing - Extending the Military's 36% Interest Rate Cap to Everyone Draft Legislation - Access to No-Fee Accounts Act. H.R. 5376 Build Back Better Act - IRS Reporting Bank Account information H.R.4277 - Overdraft Protection Act of 2021 Issues related to By Now/Pay Later Financial Products Issues related to SBA Direct 7(a) lending program H.R. 6037, To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program, and for other purposes. S. 3382, To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program. Issues related to transition from LIBOR Rate S. 3056, the Prohibiting IRS Financial Surveillance Act Issues related to FDIC Director appointment House/Senate Semi-annual Hearing with the Director of the CFPB Issues related to Cyber Security, Data Security & Breach Notification Issues related to Consumer Data Privacy Issues related to the Community Reinvestment Act Issues related to fair lending and fair banking Issues related to CFPB supervisory authority under Section 1024 Issues related to Dodd-Frank including Section 1033 Issues related to the Consumer Financial Protection Bureau H.R. 4773, the Consumer Financial Protection Commission Act Legislation related to establishing a commission at the CFPB Issues related to Interest Rate Caps on Banks Issues related to CFPB Consumer Response Portal Issues related to CFPB Taskforce on Consumer Financial Laws CFPB Section 1071 rulemaking Issues related to Underbanked/Unbanked Consumers Issues related to CFPB agency guidance Issues related to bank fees, including overdraft fees and credit card late fees. Issues related to COVID-19 pandemic H.R. 4120, To amend the Fair Credit Reporting Act to provide comprehensive reforms to the consumer credit reporting laws, and for other purposes H.R. 4277, To amend the Truth in Lending Act to establish fair and transparent practices related to the marketing and provision of overdraft coverage programs at financial institutions, and for other purposes Issues related to credit card network interchange fees. Issues related to U.S. Postal Service banking services. Issues related to the Federal Reserve Central Digital Bank Currency Issues related to the Federal Reserve Consumer checking accounts Issues related to the SBAs paycheck protection program Issues related to Pub. Law 116-136, Coronavirus Aid, Relief, and Economic Security Act Issues related to the Paycheck Protection Program H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 Issues related to the reauthorization of the Higher Education Act Issues related to the CFPBs and Department of Educations actions on student lending Issues related to disclosures for federal student loans Legislation related to student loan refinancing programs Issues related to bankruptcy protections for student loans Issues related to federal student loan reform H.R. 2498, Private Loan Disability Discharge Act of 2021 Issues related to AML-BSA Reform Issues related to FinCEN CDD Rule Issues related to Appropriations H.R. 4345, Financial Services and General Government Appropriations Act, 2022 H.R. 4350/S. 2792, National Defense Authorization Act for Fiscal Year 2022 S. Con. Res. 144616, A concurrent resolution setting forth the congressional budget for the United States Government for fiscal year 2022 and setting forth the appropriate budgetary levels for fiscal years 2023 through 2031 Issues related to the Fair Credit Reporting Act H.R. 3642 (116th Cong.), Improving Credit Reporting for All Consumers Act H.R. 953 (116th Cong.), To prohibit consumer reporting agencies from including adverse information in certain consumer reports, and from making adverse determinations relating to security clearances, with respect to certain individuals affected by the Government shutdown, and for other purposes. H.R. 1500 (116th Cong.), Consumers First Act Issues related to the Comprehensive Consumer Credit Reporting Reform Act of 2019 H.R. 4120, Comprehensive Credit Reporting Enhancement, Disclosure, Innovation, and Transparency Act of 2021 Draft Legislation - Protecting Your Credit Score Act of 2021 Issues related to the Community Reinvestment Act Issues related to financial regulatory coordination Issues related to SBA 7(a) Loan Program and fees H.R. 5050 (116th Cong.), the Veterans and Consumers Fair Credit Act Issues related to the Fair Housing Act Issues related to FinTech Issues related to the E-SIGN Act Issues related to the Bank Secrecy Act and Anti-Money Laundering Issues related to the Counter Terrorism & Illicit Finance Act S. 2563 (116th Cong.), the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act Issues related to Parent Companies of Industrial Banks and Industrial Loan Companies Regulations: Equal Credit Opportunity issues, Regulation B, 12 CFR Part 1002 Home Mortgage Disclosure Act Issues, Regulation C, 12 CFR Part 1003 Fair Debt Collection Practices Issues, Regulation F, 12 CFR Part 1006 Privacy Issues, 12 CFR Parts 40, 216, 332, 1016 Fair Credit Reporting Issues, 12 CFR Parts 41, 171, 334, 1022 Truth in Lending Issues, Regulation Z, 12 CFR Part 1026 Regulations related to the Dodd-Frank Act, Pub. L. No. 111-203 Issues related to the Higher Education Act Issues related to Electronic Fund Transfer Act, regulation E, 15 U.S.C. 1693 Issues related to FDIC Deposit Insurance Issues related to the Paperwork Reduction Act Issues related to the Military Lending Act Community Reinvestment Act Regulations & Q&A issues Issues related to the Servicemembers Civil Relief Act Issues related to Small Business Act Issues related to the Bank Secrecy Act and Anti-Money Laundering rules Issues related to Section 1033 of Dodd-Frank Issues related to Overdraft and non-sufficient funds (NSF) fees Issues related to Fintech oversight Issues related to Buy Now Pay Later Issues related to CFPB Credit Card Safe Harbor fee Issues related to Section 1071 Small Business Data Collection Issues related to UDAAP exam manual changes

H.R. 6037/S. 3382, To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program, and for other purposes. H.R. 6054, Small Business Lending Disclosure Act of 2021 P.L. 116-260, Consolidated Appropriations Act, 2021, Treatment of Economic Injury Disaster Loans (EIDL); specifically, the covenants required by the Small Business Administration (SBA) 1071 Rulemaking; CFPB-2021-0015; impact on secured finance, particularly around trade credit

Client expense: Not reported · Firm income: $10,000

Government targets: Consumer Financial Protection Bureau (CFPB), HOUSE OF REPRESENTATIVES, SENATE

Paycheck Protection Program H.R. 1799 / S. 723, PPP Extension Act H.R. 6037, To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program. H.R. 6054, Small Business Lending Disclosure Act

Client expense: $2,870,000 · Firm income: Not reported

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)

H.R. 6037 Prohibit SBA 7(a) Direct Lending H.R. 6307 Protecting Access to Credit for Small Business Act H.R. 7768 Farm Credit Administration Independence Authority Act S. 3382 Protecting Access to Credit for Small Business Act CARES Act, Paycheck Protection Program (PPP) Implementation PPP Forgiveness Process PPP Modifications to Program SBA 7(a) Program Funding and Terms SBA COVID-19 Lending Programs SBA Direct Lending

Client expense: $718,825 · Firm income: Not reported

H.R. 6037/S. 3382, To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program, and for other purposes. H.R. 6054, Small Business Lending Disclosure Act of 2021 P.L. 116-260, Consolidated Appropriations Act, 2021, Treatment of Economic Injury Disaster Loans (EIDL); specifically, the covenants required by the Small Business Administration (SBA) 1071 Rulemaking; CFPB-2021-0015; impact on secured finance, particularly around trade credit

Client expense: Not reported · Firm income: $10,000

Government targets: Consumer Financial Protection Bureau (CFPB), HOUSE OF REPRESENTATIVES, SENATE

Paycheck Protection Program H.R. 1799 / S. 723, PPP Extension Act H.R. 6037, To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program. H.R. 6054, Small Business Lending Disclosure Act

Client expense: $1,740,000 · Firm income: Not reported

Paycheck Protection Program H.R. 1799 / S. 723, PPP Extension Act H.R. 6037, To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program.

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

3/8 Senate Banking Hearing: Examining Mandatory Arbitration in Financial Service Products H.R. 963 Forced Arbitration Injustice Repeal (FAIR) Act of 2022 3/31 House Financial Services Subcommittee on Consumer Protection and Financial Institutions Hearing- The End of Overdraft Fees? Examining the Movement to Eliminate the Fees Costing Consumers Billions H.R. 8152 - American Data Privacy and Protection Act H.R. ____ - Protecting Consumers From Payment Scams Act Issues related to Section 1034 of Dodd-Frank Act Issues related to CFPB Credit Card Late Fees and Late Payments H.R.7412 - Transparency in CFPB Cost-Benefit Analysis Act H.R.6802 - Preventing Racial Profiling in Lending Act H.R.6732 - Small LENDER Act H.R.7352 - PPP and Bank Fraud Enforcement Harmonization Act of 2022 Issues related to 7/29 Senate Banking Hearing - Extending the Military's 36% Interest Rate Cap to Everyone Draft Legislation - Access to No-Fee Accounts Act. H.R. 5376 Build Back Better Act - IRS Reporting Bank Account information H.R.4277 - Overdraft Protection Act of 2021 Issues related to By Now/Pay Later Financial Products Issues related to SBA Direct 7(a) lending program H.R. 6037, To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program, and for other purposes. S. 3382, To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program. Issues related to transition from LIBOR Rate S. 3056, the Prohibiting IRS Financial Surveillance Act Issues related to FDIC Director appointment House/Senate Semi-annual Hearing with the Director of the CFPB Issues related to Cyber Security, Data Security & Breach Notification Issues related to Consumer Data Privacy Issues related to the Community Reinvestment Act Issues related to fair lending and fair banking Issues related to CFPB supervisory authority under Section 1024 Issues related to Dodd-Frank including Section 1033 Issues related to the Consumer Financial Protection Bureau H.R. 4773, the Consumer Financial Protection Commission Act Legislation related to establishing a commission at the CFPB Issues related to Interest Rate Caps on Banks Issues related to CFPB Consumer Response Portal Issues related to CFPB Taskforce on Consumer Financial Laws CFPB Section 1071 rulemaking Issues related to Underbanked/Unbanked Consumers Issues related to CFPB agency guidance Issues related to bank fees, including overdraft fees and credit card late fees. Issues related to COVID-19 pandemic H.R. 4120, To amend the Fair Credit Reporting Act to provide comprehensive reforms to the consumer credit reporting laws, and for other purposes H.R. 4277, To amend the Truth in Lending Act to establish fair and transparent practices related to the marketing and provision of overdraft coverage programs at financial institutions, and for other purposes Issues related to credit card network interchange fees. Issues related to U.S. Postal Service banking services. Issues related to the Federal Reserve Central Digital Bank Currency Issues related to the Federal Reserve Consumer checking accounts Issues related to the SBAs paycheck protection program Issues related to Pub. Law 116-136, Coronavirus Aid, Relief, and Economic Security Act H.R. 6800 (116th Cong.), Health and Economic Recovery Omnibus Emergency Solutions H.R. 7010 (116th Cong.), Paycheck Protection Program Flexibility Act of 2020 S. 4117 (116th Cong.), Paycheck Protection Program Small Business Forgiveness Act H.R. 7777 (116th Cong.), Paycheck Protection Small Business Forgiveness Act H.R. 266 (116th Cong.), Paycheck Protection Program and Health Care Enhancement Act H.R. 8406 (116th Cong.), The Heroes Act H.R. 8265 (116th Cong.), To amend the Small Business Act and the CARES Act to establish a program for second draw loans and make other modifications to the paycheck protection program, and for other purposes. S. 4321 (116th Cong.), Continuing Small Business Recovery and Paycheck Protection Program Act H.R. 1319, American Rescue Plan Act of 2021 COVID-19 relief related amendments to S. 178 (116th Cong.) Issues related to the Paycheck Protection Program H.R. 133, Coronavirus Response and Relief Supplemental Appropriations Act H.R. 6332 (116th Cong.), Relief for Consumers During COVID-19 Act of 2020 H.R. 6370, the Disaster Protection for Workers' Credit Act (116th Congress) H.R. 6316, the Emergency Relief for Student Borrowers Act of 2020 (116th Congress) H.R. 1657, Ending Debt Collection Harassment Act of 2021 H.J. Res. _____, Resolution of Disapproval on the OCCs National Banks and Federal Savings Associations as Lenders Final Rule. H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 Issues related to the reauthorization of the Higher Education Act Issues related to the CFPBs and Department of Educations actions on student lending Issues related to disclosures for federal student loans Legislation related to student loan refinancing programs Issues related to bankruptcy protections for student loans Issues related to federal student loan reform H.R. 1161 & S. 2015 (116th Cong.), The Student Loan Disclosure Modernization Act H.R. 811 & S. 234 (116th Cong.), Transparency in Student Lending Act H.R. 3621 (116th Cong.), Student Borrower Credit Improvement Act H.R. 3622 (116th Cong.), Restoring Unfairly Impaired Credit and Protecting Consumers Act H.R. 2674 (116th Cong.), the College Affordability Act H.R. 5294 (116th Cong.), Student Borrower Protection Act of 2019 H.R. 2648 (116th Cong.), Student Borrower Bankruptcy Relief Act of 2019 H.R. 2498, Private Loan Disability Discharge Act of 2021 Issues related to AML-BSA Reform Issues related to FinCEN CDD Rule Issues related to Appropriations H.R. 4345, Financial Services and General Government Appropriations Act, 2022 H.R. 4350/S. 2792, National Defense Authorization Act for Fiscal Year 2022 S. Con. Res. 144616, A concurrent resolution setting forth the congressional budget for the United States Government for fiscal year 2022 and setting forth the appropriate budgetary levels for fiscal years 2023 through 2031 Issues related to the Fair Credit Reporting Act H.R. 3642 (116th Cong.), Improving Credit Reporting for All Consumers Act H.R. 953 (116th Cong.), To prohibit consumer reporting agencies from including adverse information in certain consumer reports, and from making adverse determinations relating to security clearances, with respect to certain individuals affected by the Government shutdown, and for other purposes. H.R. 1500 (116th Cong.), Consumers First Act Issues related to the Comprehensive Consumer Credit Reporting Reform Act of 2019 H.R. 4120, Comprehensive Credit Reporting Enhancement, Disclosure, Innovation, and Transparency Act of 2021 Draft Legislation - Protecting Your Credit Score Act of 2021 Issues related to the Community Reinvestment Act Issues related to the OCC, Federal Reserve, and FDIC modernization of the Community Reinvestment Act Issues related to financial regulatory coordination Issues related to SBA 7(a) Loan Program and fees H.R. 3614 (116th Cong.), Restricting Credit Checks for Employment Decisions Act H.R. 3618 (116th Cong.), Free Credit Scores for Consumer Act of 2019 H.R. 5050 (116th Cong.), the Veterans and Consumers Fair Credit Act Issues related to the Fair Housing Act Issues related to FinTech Issues related to the E-SIGN Act S. 4159 (116th Cong.), E-SIGN Modernization Act of 2020 Issues related to the Bank Secrecy Act and Anti-Money Laundering Issues related to the Counter Terrorism & Illicit Finance Act H.R. 2513 (116th Cong.), the Corporate Transparency Act of 2019 H.R. 2514 (116th Cong.), the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 S. 2563 (116th Cong.), the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act Issues related to Parent Companies of Industrial Banks and Industrial Loan Companies Regulations: Equal Credit Opportunity issues, Regulation B, 12 CFR Part 1002 Home Mortgage Disclosure Act Issues, Regulation C, 12 CFR Part 1003 Fair Debt Collection Practices Issues, Regulation F, 12 CFR Part 1006 Privacy Issues, 12 CFR Parts 40, 216, 332, 1016 Fair Credit Reporting Issues, 12 CFR Parts 41, 171, 334, 1022 Truth in Lending Issues, Regulation Z, 12 CFR Part 1026 Regulations related to the Dodd-Frank Act, Pub. L. No. 111-203 Issues related to the Higher Education Act Issues related to Electronic Fund Transfer Act, regulation E, 15 U.S.C. 1693 Issues related to FDIC Deposit Insurance Issues related to the Paperwork Reduction Act Issues related to the Military Lending Act Community Reinvestment Act Regulations & Q&A issues Issues related to the Servicemembers Civil Relief Act Issues related to Small Business Act Issues related to the Bank Secrecy Act and Anti-Money Laundering rules Issues related to Section 1033 of Dodd-Frank Issues related to Overdraft and non-sufficient funds (NSF) fees Issues related to Overdraft Issues related to Fintech oversight Issues related to Buy Now Pay Later Issues related to CFPB Credit Card Safe Harbor fee Issues related to Section 1071 Small Business Data Collection Issues related to UDAAP exam manual changes

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. 6037 Prohibit SBA 7(a) Direct Lending H.R. 6307 Protecting Access to Credit for Small Business Act H.R. 7768 Farm Credit Administration Independence Authority Act S. 3382 Protecting Access to Credit for Small Business Act CARES Act, Paycheck Protection Program (PPP) Implementation PPP Forgiveness Process PPP Modifications to Program SBA 7(a) Program Funding and Terms SBA COVID-19 Lending Programs SBA Direct Lending

Client expense: $1,840,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Small Business Administration (SBA)

H.R. 6037 Prohibit SBA 7(a) Direct Lending H.R. 6307 Protecting Access to Credit for Small Business Act S. 3382 Protecting Access to Credit for Small Business Act CARES Act, Paycheck Protection Program (PPP) Implementation PPP Forgiveness Process PPP Modifications to Program SBA 7(a) Program Funding and Terms SBA COVID-19 Lending Programs SBA Direct Lending

Client expense: $690,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Small Business Administration (SBA)

H.R. 963 FAIR Act 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. 2471 Consolidated Appropriations Act 2022 Cyber Incident Reporting for Critical Infrastructure Act of 2022, Adjustable Interest Rate (LIBOR) 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. 3076 Postal Service Reform Act, support for Senate Amendment 4066 (Toomey) to prohibit postal banking 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. 4616 The Adjustable Interest Rate (LIBOR) Act H.R. 5376 The Build Back Better Act H.R. 5440 Cyber Incident Reporting for Critical Infrastructure 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. 6145 Community Bank Relief Act H.R. 6307 Protecting Access to Credit for Small Businesses Act H.R. 6415 To amend the Federal Reserve Act to prohibit the Federal reserve banks from offering certain products or services directly to an individual (CBDC) 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 S. 910 SAFE Banking Act S. 1684 Federal Home Loan Banks Mission Implementation Act S. 2407 Cyber Incident Notification Act of 2021 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. 3441 CDFI Bond Guarantee Program Improvement Act S. 3715 E-Sign Modernization Act S. 3745 TAILOR Act S.3844 Economic Continuity and Stability Act (LIBOR Transition) S. 3954 Ban CBDC S. Amend 3099 - Amendment to the Senate Budget Resolution to bar new IRS reporting Advancing Technologies to Support Inclusion Act (draft) Arbitration Bank Capital and Accounting Relief Bank Secrecy Act/Anti-Money Laundering Rules/Legislation, including Beneficial Ownership Issue Banking Services Fees Cannabis Banking CARES Act, Paycheck Protection Program Implementation CDFI Certification Consultation Act (draft) Central Bank Digital Currency Climate Risk Disclosure Requirements Climate-Related Financial Regulation Community Bank Access to Capital Community Bank Leverage Ratio Community Development Financial Institutions (CDFI) Fund Appropriations 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 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 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 Federal Reserve Accounts for Consumers Financial Sanctions 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 OCC Proposed Payments Charter Overdraft Fees Overdraft Protection Payment semi-conductor chip disruptions Postal Banking Promoting and Advancing Communities of Color Through Inclusive Lending Act (draft) 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 Secure Notarization Simplification of Deposit Insurance Rules Small Business Loan Data Collection--CFPB Implementation of Dodd-Frank Act Section 1071 Stablecoins Stablecoin Innovation and Protection Act of 2022 (draft) Supporting the Creation of Diverse and Mission-Driven Community Financial Institutions Act(draft) Tailored Supervision of Community Banks (draft legislation) The Strengthening Cybersecurity for the Financial Sector Act (draft legislation) Understanding Community Financial Institutions Impact in Underserved Communities Act(draft)

Paycheck Protection Program H.R. 1799 / S. 723, PPP Extension Act H.R. 6037, To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program.

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

3/8 Senate Banking Hearing: Examining Mandatory Arbitration in Financial Service Products H.R. 963 Forced Arbitration Injustice Repeal (FAIR) Act of 2022 3/31 House Financial Services Subcommittee on Consumer Protection and Financial Institutions Hearing- The End of Overdraft Fees? Examining the Movement to Eliminate the Fees Costing Consumers Billions H.R. 7352 PPP and Bank Fraud Enforcement Harmonization Act of 2022 7/29 Senate Banking Hearing - Extending the Military's 36% Interest Rate Cap to Everyone Draft Legislation - Access to No-Fee Accounts Act. H.R. 5376 Build Back Better Act - IRS Reporting Bank Account information H.R.4277 - Overdraft Protection Act of 2021 Issues related to By Now/Pay Later Financial Products Issues related to SBA Direct 7(a) lending program H.R. 6037, To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program, and for other purposes. S. 3382, To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program. Issues related to the transition from LIBOR Rate S. 3056, the Prohibiting IRS Financial Surveillance Act House/Senate Semi-annual Hearing with the Director of the CFPB Issues related to Cyber Security, Data Security & Breach Notification Issues related to Consumer Data Privacy Issues related to the Community Reinvestment Act Issues related to HUD disparate-impact rule Issues related to Government National Mortgage Association requirements for mortgage-backed securities issuers Issues related to third-party risk management Issues related to the use of artificial intelligence Issues related to CFPB supervisory authority under Section 1024 Issues related to Dodd-Frank including Section 1033 Issues related to the Consumer Financial Protection Bureau H.R. 4773, the Consumer Financial Protection Commission Act Legislation related to establishing a commission at the CFPB Issues related to Interest Rate Caps on Banks Issues related to CFPB Consumer Response Portal Issues related to CFPB Taskforce on Consumer Financial Laws CFPB Section 1071 rulemaking Issues related to the Ability to Repay Rule, Qualified Mortgage Standards Issues related to Underbanked/Unbanked Consumers Issues related to CFPB agency guidance Issues related to bank fees, including overdraft fees. Issues related to the establishment of a bank tax. Issues related to financial institution charters, specifically ILC charters Issues related to the COVID-19 pandemic H.R. 4120, To amend the Fair Credit Reporting Act to provide comprehensive reforms to the consumer credit reporting laws, and for other purposes H.R. 4277, To amend the Truth in Lending Act to establish fair and transparent practices related to the marketing and provision of overdraft coverage programs at financial institutions, and for other purposes Issues related to U.S. Postal Service banking services. Issues related to financial data reporting to the IRS. Issues related to IRS Customer Reporting Requirements for Financial Institutions Issues related to the Federal Reserve Central Digital Bank Currency Issues related to the Federal Reserve Consumer checking accounts Issues related to the SBAs paycheck protection program Issues related to Pub. Law 116-136, Coronavirus Aid, Relief, and Economic Security Act H.R. 6800 (116th Cong.), Health and Economic Recovery Omnibus Emergency Solutions H.R. 7010 (116th Cong.), Paycheck Protection Program Flexibility Act of 2020 S. 4117 (116th Cong.), Paycheck Protection Program Small Business Forgiveness Act H.R. 7777 (116th Cong.), Paycheck Protection Small Business Forgiveness Act H.R. 266 (116th Cong.), Paycheck Protection Program and Health Care Enhancement Act H.R. 8406 (116th Cong.), The Heroes Act H.R. 8265 (116th Cong.), To amend the Small Business Act and the CARES Act to establish a program for second draw loans and make other modifications to the paycheck protection program, and for other purposes. S. 4321 (116th Cong.), Continuing Small Business Recovery and Paycheck Protection Program Act H.R. 1799, PPP Extension Act of 2021 H.R. 1319, American Rescue Plan Act of 2021 COVID-19 relief-related amendments to S. 178 (116th Cong.) Issues related to the Heal, Economic Assistance, Liability Protection, and Schools Act Issues related to the Paycheck Protection Program Issues related to OCC Fair Access Proposal Issues related to OCC Modeled Income H.R. 133, Coronavirus Response and Relief Supplemental Appropriations Act H.R. 6332 (116th Cong.), Relief for Consumers During COVID-19 Act of 2020 H.R. 6361, the Relief for Small Businesses and Nonprofits Act (116th Congress) H.R. 6370, the Disaster Protection for Workers' Credit Act (116th Congress) H.R. 6316, the Emergency Relief for Student Borrowers Act of 2020 (116th Congress) H.R. 1657, Ending Debt Collection Harassment Act of 2021 H.J. Res. _____, Resolution of Disapproval on the OCCs National Banks and Federal Savings Associations as Lenders Final Rule. Issues related to economic impact payments distributed and subsequent garnishments pursuant to the Coronavirus Aid, Relief, and Economic Security Act or CARES Act Issues related to the transition away from LIBOR H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 Issues related to the reauthorization of the Higher Education Act Issues related to the CFPBs and Department of Educations actions on student lending Issues related to disclosures for federal student loans Legislation related to student loan refinancing programs Issues related to bankruptcy protections for student loans Issues related to federal student loan reform H.R. 1161 & S. 2015 (116th Cong.), The Student Loan Disclosure Modernization Act H.R. 811 & S. 234 (116th Cong.), Transparency in Student Lending Act H.R. 3621 (116th Cong.), Student Borrower Credit Improvement Act H.R. 3622 (116th Cong.), Restoring Unfairly Impaired Credit and Protecting Consumers Act H.R. 2674 (116th Cong.), the College Affordability Act H.R. 5294 (116th Cong.), Student Borrower Protection Act of 2019 H.R. 2648 (116th Cong.), Student Borrower Bankruptcy Relief Act of 2019 H.R. 2498, Private Loan Disability Discharge Act of 2021 Issues related to Appropriations H.R. 4345, Financial Services and General Government Appropriations Act, 2022 H.R. 4350/S. 2792, National Defense Authorization Act for Fiscal Year 2022 S. Con. Res. 144616, A concurrent resolution setting forth the congressional budget for the United States Government for the fiscal year 2022 and setting forth the appropriate budgetary levels for fiscal years 2023 through Issues related to the Fair Credit Reporting Act H.R. 3642 (116th Cong.), Improving Credit Reporting for All Consumers Act H.R. 953 (116th Cong.), To prohibit consumer reporting agencies from including adverse information in certain consumer reports, and from making adverse determinations relating to security clearances, with respect to certain individuals affected by the Government shutdown, and for other purposes. H.R. 1500 (116th Cong.), Consumers First Act Issues related to the Comprehensive Consumer Credit Reporting Reform Act of 2019 H.R. 4120, Comprehensive Credit Reporting Enhancement, Disclosure, Innovation, and Transparency Act of 2021 Draft Legislation - Protecting Your Credit Score Act of 2021 Issues related to the Community Reinvestment Act Issues related to financial regulatory coordination Issues related to SBA 7(a) Loan Program and fees H.R. 3614 (116th Cong.), Restricting Credit Checks for Employment Decisions Act H.R. 3618 (116th Cong.), Free Credit Scores for Consumer Act of 2019 H.R. 5050 (116th Cong.), the Veterans and Consumers Fair Credit Act Issues related to the Fair Housing Act Issues related to FinTech Issues related to the E-SIGN Act S. 4159 (116th Cong.), E-SIGN Modernization Act of 2020 Issues related to the Bank Secrecy Act and Anti-Money Laundering Issues related to the Counter-Terrorism & Illicit Finance Act H.R. 2513 (116th Cong.), the Corporate Transparency Act of 2019 H.R. 2514 (116th Cong.), the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 S. 2563 (116th Cong.), the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act Issues related to Parent Companies of Industrial Banks and Industrial Loan Companies Regulations: Equal Credit Opportunity issues, Regulation B, 12 CFR Part 1002 Home Mortgage Disclosure Act Issues, Regulation C, 12 CFR Part 1003 Fair Debt Collection Practices Issues, Regulation F, 12 CFR Part 1006 Privacy Issues, 12 CFR Parts 40, 216, 332, 1016 Fair Credit Reporting Issues, 12 CFR Parts 41, 171, 334, 1022 Truth in Lending Issues, Regulation Z, 12 CFR Part 1026 Regulations related to the Dodd-Frank Act, Pub. L. No. 111-203 Issues related to the Higher Education Act Issues related to Electronic Fund Transfer Act, Regulation E, 15 U.S.C. 1693 Issues related to FDIC Deposit Insurance Issues related to the Paperwork Reduction Act Issues related to the Military Lending Act Community Reinvestment Act Regulations & Q&A issues Issues related to the Servicemembers Civil Relief Act Issues related to Small Business Act Issues related to the Bank Secrecy Act and Anti-Money Laundering rules Issues related to the Counter-Terrorism & Illicit Finance Act Issues related to Section 1033 of Dodd-Frank Issues related to CFPB Electronic Disclosures on Mobile Devices Issues related to Fintech oversight

H.R. 6037/S. 3382, To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program, and for other purposes. Monitored proposals around commercial lending disclosures P.L. 116-260, Consolidated Appropriations Act, 2021, Treatment of Economic Injury Disaster Loans (EIDL); specifically, the covenants required by the Small Business Administration (SBA) 1071 Rulemaking; CFPB-2021-0015; impact on secured finance, particularly around trade credit

Client expense: Not reported · Firm income: $10,000

Government targets: Consumer Financial Protection Bureau (CFPB), HOUSE OF REPRESENTATIVES, SENATE

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.

7/29 Senate Banking Hearing - Extending the Military's 36% Interest Rate Cap to Everyone Draft Legislation - Access to No-Fee Accounts Act. H.R. 5376 Build Back Better Act - IRS Reporting Bank Account information H.R.4277 - Overdraft Protection Act of 2021 Issues related to By Now/Pay Later Financial Products Issues related to SBA Direct 7(a) lending program H.R. 6037, To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program, and for other purposes. S. 3382, To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program. Issues related to the transition from LIBOR Rate S. 3056, the Prohibiting IRS Financial Surveillance Act Issues related to FDIC Director appointment House/Senate Semi-annual Hearing with the Director of the CFPB Issues related to Cyber Security, Data Security & Breach Notification Issues related to Consumer Data Privacy Issues related to the Community Reinvestment Act Issues related to HUD disparate-impact rule Issues related to Government National Mortgage Association requirements for mortgage-backed securities issuers Issues related to third-party risk management Issues related to the use of artificial intelligence Issues related to fair lending Issues related to CFPB supervisory authority under Section 1024 Issues related to Dodd-Frank including Section 1033 Issues related to the Consumer Financial Protection Bureau H.R. 4773, the Consumer Financial Protection Commission Act Legislation related to establishing a commission at the CFPB Issues related to Interest Rate Caps on Banks Issues related to CFPB Consumer Response Portal Issues related to CFPB Taskforce on Consumer Financial Laws Issues related to CFPB Small-dollar Rule CFPB Section 1071 rulemaking Issues related to Confirmation of new CFPB Director Issues related to the Ability to Repay Rule, Qualified Mortgage Standards Issues related to Underbanked/Unbanked Consumers Issues related to CFPB agency guidance Issues related to Confirmation of new OCC Comptroller Issues related to bank fees, including overdraft fees. Issues related to the establishment of a bank tax. Issues related to financial institution charters, specifically ILC charters Issues related to the COVID-19 pandemic H.R. 4120, To amend the Fair Credit Reporting Act to provide comprehensive reforms to the consumer credit reporting laws, and for other purposes H.R. 4277, To amend the Truth in Lending Act to establish fair and transparent practices related to the marketing and provision of overdraft coverage programs at financial institutions, and for other purposes Issues related to credit card network interchange fees. Issues related to U.S. Postal Service banking services. Issues related to non-compete clauses Issues related to financial data reporting to the IRS. Issues related to IRS Customer Reporting Requirements for Financial Institutions Issues related to the Federal Reserve Central Digital Bank Currency Issues related to the Federal Reserve Consumer checking accounts Issues related to the SBAs paycheck protection program Issues related to Pub. Law 116-136, Coronavirus Aid, Relief, and Economic Security Act H.R. 6800 (116th Cong.), Health and Economic Recovery Omnibus Emergency Solutions H.R. 7010 (116th Cong.), Paycheck Protection Program Flexibility Act of 2020 S. 4117 (116th Cong.), Paycheck Protection Program Small Business Forgiveness Act H.R. 7777 (116th Cong.), Paycheck Protection Small Business Forgiveness Act H.R. 266 (116th Cong.), Paycheck Protection Program and Health Care Enhancement Act H.R. 8406 (116th Cong.), The Heroes Act H.R. 8265 (116th Cong.), To amend the Small Business Act and the CARES Act to establish a program for second draw loans and make other modifications to the paycheck protection program, and for other purposes. S. 4321 (116th Cong.), Continuing Small Business Recovery and Paycheck Protection Program Act H.R. 1799, PPP Extension Act of 2021 H.R. 1319, American Rescue Plan Act of 2021 COVID-19 relief-related amendments to S. 178 (116th Cong.) Issues related to the Heal, Economic Assistance, Liability Protection, and Schools Act Issues related to the Paycheck Protection Program Issues related to OCC Fair Access Proposal Issues related to OCC Modeled Income H.R. 133, Coronavirus Response and Relief Supplemental Appropriations Act H.R. 6332 (116th Cong.), Relief for Consumers During COVID-19 Act of 2020 H.R. 6361, the Relief for Small Businesses and Nonprofits Act (116th Congress) H.R. 6370, the Disaster Protection for Workers' Credit Act (116th Congress) H.R. 6316, the Emergency Relief for Student Borrowers Act of 2020 (116th Congress) H.R. 1657, Ending Debt Collection Harassment Act of 2021 H.J. Res. _____, Resolution of Disapproval on the OCCs National Banks and Federal Savings Associations as Lenders Final Rule. Issues related to economic impact payments distributed and subsequent garnishments pursuant to the Coronavirus Aid, Relief, and Economic Security Act or CARES Act Issues related to the transition away from LIBOR H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 Issues related to the reauthorization of the Higher Education Act Issues related to the CFPBs and Department of Educations actions on student lending Issues related to disclosures for federal student loans Legislation related to student loan refinancing programs Issues related to bankruptcy protections for student loans Issues related to federal student loan reform H.R. 1161 & S. 2015 (116th Cong.), The Student Loan Disclosure Modernization Act H.R. 811 & S. 234 (116th Cong.), Transparency in Student Lending Act H.R. 3621 (116th Cong.), Student Borrower Credit Improvement Act H.R. 3622 (116th Cong.), Restoring Unfairly Impaired Credit and Protecting Consumers Act H.R. 2674 (116th Cong.), the College Affordability Act H.R. 5294 (116th Cong.), Student Borrower Protection Act of 2019 H.R. 2648 (116th Cong.), Student Borrower Bankruptcy Relief Act of 2019 H.R. 2498, Private Loan Disability Discharge Act of 2021 Issues related to AML-BSA Reform Issues related to FinCEN CDD Rule Issues related to FDIC Director appointment. Issues related to Appropriations H.R. 4345, Financial Services and General Government Appropriations Act, 2022 H.R. 4350/S. 2792, National Defense Authorization Act for Fiscal Year 2022 S. Con. Res. 144616, A concurrent resolution setting forth the congressional budget for the United States Government for the fiscal year 2022 and setting forth the appropriate budgetary levels for fiscal years 2023 through 2031 Issues related to the Fair Credit Reporting Act H.R. 3642 (116th Cong.), Improving Credit Reporting for All Consumers Act H.R. 953 (116th Cong.), To prohibit consumer reporting agencies from including adverse information in certain consumer reports, and from making adverse determinations relating to security clearances, with respect to certain individuals affected by the Government shutdown, and for other purposes. H.R. 1500 (116th Cong.), Consumers First Act Issues related to the Comprehensive Consumer Credit Reporting Reform Act of 2019 H.R. 4120, Comprehensive Credit Reporting Enhancement, Disclosure, Innovation, and Transparency Act of 2021 Draft Legislation - Protecting Your Credit Score Act of 2021 Issues related to the Community Reinvestment Act Issues related to the OCC, Federal Reserve, and FDIC modernization of the Community Reinvestment Act Issues related to financial regulatory coordination Issues related to SBA 7(a) Loan Program and fees H.R. 3614 (116th Cong.), Restricting Credit Checks for Employment Decisions Act H.R. 3618 (116th Cong.), Free Credit Scores for Consumer Act of 2019 H.R. 5050 (116th Cong.), the Veterans and Consumers Fair Credit Act Issues related to the Fair Housing Act Issues related to FinTech Issues related to the E-SIGN Act S. 4159 (116th Cong.), E-SIGN Modernization Act of 2020 Issues related to the Bank Secrecy Act and Anti-Money Laundering Issues related to the Counter-Terrorism & Illicit Finance Act H.R. 2513 (116th Cong.), the Corporate Transparency Act of 2019 H.R. 2514 (116th Cong.), the Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019 S. 2563 (116th Cong.), the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act Issues related to Parent Companies of Industrial Banks and Industrial Loan Companies Regulations: Equal Credit Opportunity issues, Regulation B, 12 CFR Part 1002 Home Mortgage Disclosure Act Issues, Regulation C, 12 CFR Part 1003 Fair Debt Collection Practices Issues, Regulation F, 12 CFR Part 1006 Privacy Issues, 12 CFR Parts 40, 216, 332, 1016 Fair Credit Reporting Issues, 12 CFR Parts 41, 171, 334, 1022 Truth in Lending Issues, Regulation Z, 12 CFR Part 1026 Regulations related to the Dodd-Frank Act, Pub. L. No. 111-203 Issues related to the Higher Education Act Issues related to Telephone Consumer Protection Act, 47 U.S.C. 227 Issues related to Electronic Fund Transfer Act, Regulation E, 15 U.S.C. 1693 Issues related to FDIC Deposit Insurance Issues related to the Paperwork Reduction Act Issues related to the Military Lending Act Community Reinvestment Act Regulations & Q&A issues Issues related to the Servicemembers Civil Relief Act Issues related to Small Business Act Issues related to the Bank Secrecy Act and Anti-Money Laundering rules Issues related to the Counter-Terrorism & Illicit Finance Act Issues related to the CFPB Request for Information Process Issues related to the FDIC Brokered deposits Rule and Interest Rule Restrictions Issues related to Section 1033 of Dodd-Frank Issues related to CFPB Electronic Disclosures on Mobile Devices Issues related to Overdraft and non-sufficient funds (NSF) fees Issues related to Overdraft Issues related to Fintech oversight Issues related to Buy Now Pay Later

H.R. 6037 Prohibit SBA 7(a) Direct Lending H.R. 6307 Protecting Access to Credit for Small Business Act S. 3382 Protecting Access to Credit for Small Business Act CARES Act, Paycheck Protection Program (PPP) Implementation PPP Forgiveness Process PPP Modifications to Program SBA 7(a) Program Funding and Terms SBA COVID-19 Lending Programs SBA Direct Lending

Client expense: $1,230,000 · 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. 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)

Paycheck Protection Program H.R. 1799 / S. 723, PPP Extension Act H.R. 6037, To prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program.

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

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act which provides this legal safe harbor. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Community Bank Positions on Emerging Issues Customer Data Sharing - CFPB Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection - CFPB Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception. Reporting Beneficial Ownership Information - FinCEN Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bailouts, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - Potential proposal in the Build Back Better Act (BBB) (commonly known as the IRS Reporting Plan) to force banks (and other financial service providers) to collect and report new and detailed information to the Internal Revenue Service (IRS) on consumer and business account activity (House and Senate) Proposal in legislation known as Build Back Better Act (BBB) to allocate funds to permit the U.S. Small Business Administration to directly originate and disburse SBA 7(a) loans (House and Senate) H.R. 6037 (all sections) which is legislation to prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program (House and Senate) H.R. 1977 - Enhancing Credit Opportunities in Rural America Act of 2021 (all sections) which is legislation to exempt from the calculation of interest received by a lender from real estate loans secured by agricultural real estate that is used in the production of agricultural products or from loans secured by a single-family principal residence in rural areas (House) Letters - Comment Letter to the Farm Credit Administration regarding: Request for Input on Strategic Plan (Farm Credit Administration) Action Alerts - Action Alert regarding proposal in legislation known as Build Back Better Acct (BBB) to allocate funds to permit the U.S. Small Business Administration to directly originate and disburse SBA 7(a) loans (House and Senate) Miscellaneous - Webinar on credit unions issues including reigning-in the expansionist agenda of the largest credit unions and tax-exempt credit unions buying taxpaying community banks (House)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce, because of the risks they pose to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole that excludes their holding companies from being supervised and regulated by the Federal Reserve must be closed. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act which provides this legal safe harbor. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Community Bank Positions on Emerging Issues Fintechs and Special Purpose Fintech National Bank (SPNBs) - OCC Fintechs, including the OCCs SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) - FASB Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing - CFPB Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection - CFPB Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception. Reporting Beneficial Ownership Information - FinCEN Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax - Congress Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - Potential proposal in the Build Back Better Act (BBB) (commonly known as the IRS Reporting Plan) to force banks (and other financial service providers) to collect and report new and detailed information to the Internal Revenue Service (IRS) on consumer and business account activity (House and Senate) Proposal in legislation known as Build Back Better Act (BBB) to allocate funds to permit the U.S. Small Business Administration to directly originate and disburse SBA 7(a) loans (House and Senate) H.R. 5912 - Close the ILC Loophole Act (all sections) which is legislation to reform the regulation of industrial loan companies and their parent companies (House) H.R. 1977 - Enhancing Credit Opportunities in Rural America Act of 2021 (all sections) which is legislation to exempt from the calculation of interest received by a lender from real estate loans secured by agricultural real estate that is used in the production of agricultural products or from loans secured by a single-family principal residence in rural areas (House) H.R. 6037 (all sections) which is legislation to prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program (House and Senate) Letters - Comment Letter to the Farm Credit Administration regarding: Request for Input on Strategic Plan (Farm Credit Administration) Comment Letter to the Federal Reserve, OCC and the FDIC regarding: Proposed Interagency Guidance on Third-Party Relationships - Risk Management (Federal Reserve Docket No. OP-1752, FDIC RIN 3064-ZA26, and OCC Docket No. OCC-2021-0011) (Federal Reserve, OCC and FDIC) Action Alerts - Action Alert regarding proposal in legislation known as Build Back Better Acct (BBB) to allocate funds to permit the U.S. Small Business Administration to directly originate and disburse SBA 7(a) loans (House and Senate) Miscellaneous - Webinar on credit unions issues including reigning-in the expansionist agenda of the largest credit unions and tax-exempt credit unions buying taxpaying community banks (House) Professor Saule Omarova nomination to be Comptroller of the Currency (OCC) (Senate)

CBAI 2021 Federal Policy Priorities - Community Bank Response to the COVID-19 Pandemic COVID-19 has focused community bank efforts on helping their individual and small business customers and their communities weather the virus crisis and assist in the recovery effort. This was a commitment above and beyond what was normally expected, but one which community bankers were happy to fulfill. Community banks stepped-up during the crisis despite the many challenges and frustrations they encountered. They should be commended for what they are doing, treated fairly and equally, encouraged to do more, and not penalized for successfully performing their essential function. The Independent Community Bankers of Americas Legislative and Regulatory Agenda Contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity CBAI joins the Independent Community Bankers of America (ICBA) in supporting a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in every corner of the country. Additional Meaningful Regulatory Relief for Community Banks Community bankers seek additional regulatory relief including on several fronts (i.e., BSA reform, CTRs, and SARs) to permit them to better serve their customers and communities while proudly fulfilling their reasonable responsibility to identify and report illicit actors. The Community Bank Position on Credit Unions and Their Expanded Powers Credit unions have long-since strayed from their founding purpose of serving individuals of modest means and with a common bond. They blatantly abuse their competitive advantages and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks is a recent and disturbing trend that negatively impacts all taxpayers. This escalation of credit unions abusing of their tax-exemption should prompt Congress to Wake Up and act - NOW. This abuse is an existential threat to community banks and the communities they serve. The Community Bank Position on the Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long-since strayed from its founding purposes, blatantly abusing its competitive advantages against community banks. The FCS is the only GSE that competes directly with community banks. This blatant and continuing discrimination against community banks must end and FCS competitive advantages must be reined-in, and the playing field leveled for community banks. Closing the Industrial Loan Company (ILC) Regulatory Loophole ILCs represent the unacceptable mixing of banking and commerce, because of the risks they pose to the financial system, our economy and American taxpayers. ILCs are the functional equivalent of banks and should be properly regulated. The loophole that excludes their holding companies from being supervised and regulated by the Federal Reserve must be closed. The Federal Reserves Role in Payments System Improvement A fast and secure payments system is the very foundation of financial services and economy and must be modernized. The payments system must not be monopolized by The Clearing House and its 25 large bank owners that endangered our financial system and the entire economy during the financial crisis. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system. The Federal Reserve must be supported in its development of the FedNow Service to ensure that all participants have access to a real-time system on a fair and impartial basis. Modernizing the Community Reinvestment Act (CRA) The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of every financial institutions performance in serving their communities. A modernization of the CRA that does not encompass credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks) will be a sham. All the banking regulators must agree on joint final rule to modernize the CRA. Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, a safe harbor from federal sanctions for financial institutions that choose to serve legally compliant cannabis-related business in states where cannabis is legal is a matter of public safety. CBAI has expressed its support in Congress for the Secure and Fair Enforcement Banking Act which provides this legal safe harbor. De Novo Community Bank Formation, the Dual Banking System and Charter Choice Newly chartered (de novo) community banks are vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of banking industry consolidation. Many new banks must be chartered each year to help maintain the vitality of the community banking profession. The dual banking system, where chartering and supervision is divided between the federal government and the states is important and must be maintained. Community banks should be able to choose the banking charter that best fits their unique business model. A banking system with multi-agency (state and federal) regulators and charter choice provides the necessary checks and balances as well as improved rulemaking on complex issues. Sound Principles for GSE Reform The seemingly endless and ongoing period of government ownership and control of Fannie and Freddie must come to an end. GSE reform remains critically important to the future of the housing market and the U.S. economy. Community banks depend on the GSE for direct access to the secondary market. The GSEs must provide a steady and reliable source of funding for home mortgage lending for lenders of all sizes and through all economic cycles. This is particularly critical to maintaining liquidity when the markets are experiencing financial stress. The Federal Home Loan Banks Most community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions, and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable, and reliable sources of funding for their members. Agriculture and Rural America A vibrant rural economy is vital to Americas prosperity. The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from cuts or any adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. Enhanced Data, Cyber and Payment Card Security (Data Security) Enhanced security standards should be enforced through a tiered system where the more restrictive rules and are imposed on the largest and most critical members of the financial system and economy where their lapses pose the greatest threat to the largest number of consumers. Core data security principals in standards enacted by legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards; and any new data security standard proposals should ensure that community banks are not overburdened with redundant standards. Consumer Financial Protection Bureau Reform and Meaningful Exemptions for Community Banks Regulations promulgated by the CFPB must provide community banks with the flexibility to meet the needs of its customers and they must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. A one-size-fits-all approach to CFPB regulations harms the successful community bank business model. In reforming the CFPB, the single Director governance should be replaced by a five-member board or commission; a broader definition of firms that grant credit should be subject to the CFPB rules, they should be robustly supervised and examined; and the focus of any enhanced regulation of financial products should be on the mega banks and financial firms, the unregulated shadow financial industry and emerging Fintech companies. The CFPB has the statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, but to-date the Bureau has been far too reticent to do so. The effective use of this authority will ensure community banks continue to be a healthy alternative to large banks and non-banks for consumers seeking to use responsible financial service providers. The Community Bank Positions on Emerging Issues Fintechs and Special Purpose Fintech National Bank (SPNBs) - OCC Fintechs, including the OCCs SPNBs, raise many concerns. They cannot have the advantages of a bank charter with limited requirements, regulations, and liability. Postal Banking - Congress Postal banking is misguided and any entry of the USPS (Postal Service) into banking services is a significant government-sponsored, competitive threat to the viability of tax-paying community banks. Current Expected Credit Loss Model (CECL) - FASB Community bankers and Congress must continue to be vigilant to assure the CECL Model implementation provides a clear, practical, and easy-to-use methodologies for calculating expected losses which can be seamlessly incorporated into existing processes for community banks. Customer Data Sharing - CFPB Community banks are financially sound and take great care in protecting consumer privacy. Non-bank entities must be held responsible for ensuring the safety of the customer information they are accessing and be able to satisfy the liability for any financial harm which they cause community banks and their consumers. Small Business Data Collection - CFPB Small business lending data clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks, and Section 1071 should either be repealed, or community banks should be provided with a meaningful exception. Reporting Beneficial Ownership Information - FinCEN Provisions in the NDAA in the 116th Congress shifted the burden of collecting and reporting beneficial ownership to FinCEN. This transfer must be accomplished expeditiously. Financial Transaction Tax - Congress Tax laws should encourage and promote robust economic activity and a thriving community banking sector, not impose new bank-specific fees, punitive new levies, transaction taxes, limitations on the deductibility of expenses, revenue offsets or pay-fors that target the banking industry. Rather, there should be parity among all financial service providers; there should be tax incentives for community banks serving low- and moderate-income individuals, small businesses, and small farms; and there should be a tax credit equivalent to the cost of community bank compliance with BSA compliance. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms to Protect Our Financial System, the Economy, and American Taxpayers from Future Bailouts The financial crisis, taxpayer bail-outs, and subsequent recession was caused by the misconduct of the nations largest banks and financial firms. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized. (House and Senate) Legislation and Regulation - Potential proposal in the Build Back Better Act (BBB) (commonly known as the IRS Reporting Plan) to force banks (and other financial service providers) to collect and report new and detailed information to the Internal Revenue Service (IRS) on consumer and business account activity (House and Senate) Proposal in legislation known as Build Back Better Act (BBB) to allocate funds to permit the U.S. Small Business Administration to directly originate and disburse SBA 7(a) loans (House and Senate) H.R. 5912 - Close the ILC Loophole Act (all sections) which is legislation to reform the regulation of industrial loan companies and their parent companies (House) H.R. 1977 - Enhancing Credit Opportunities in Rural America Act of 2021 (all sections) which is legislation to exempt from the calculation of interest received by a lender from real estate loans secured by agricultural real estate that is used in the production of agricultural products or from loans secured by a single-family principal residence in rural areas (House) H.R. 6037 (all sections) which is legislation to prohibit the Administrator of the Small Business Administration from directly making loans under the 7(a) loan program (House and Senate) Letters - Comment Letter to the Farm Credit Administration regarding: Request for Input on Strategic Plan (Farm Credit Administration) Comment Letter to the Federal Reserve, OCC and the FDIC regarding: Proposed Interagency Guidance on Third-Party Relationships - Risk Management (Federal Reserve Docket No. OP-1752, FDIC RIN 3064-ZA26, and OCC Docket No. OCC-2021-0011) (Federal Reserve, OCC and FDIC) Action Alerts - Action Alert regarding proposal in legislation known as Build Back Better Acct (BBB) to allocate funds to permit the U.S. Small Business Administration to directly originate and disburse SBA 7(a) loans (House and Senate) Miscellaneous - Webinar on credit unions issues including reigning-in the expansionist agenda of the largest credit unions and tax-exempt credit unions buying taxpaying community banks (House) Professor Saule Omarova nomination to be Comptroller of the Currency (OCC) (Senate)