CFPB–IG Reform Act of 2021

H.R. 7412 - Transparency in CFPB Cost-Benefit Analysis Act. The bill sets forth information required to be included in a rulemaking made by the Consumer Financial Protection Bureau (CFPB). Specifically, the CFPB must publish a justification of the proposed rulemaking; a quantitative and qualitative assessment of all anticipated direct and indirect costs and benefits; alternatives to the proposed rulemaking; impacts on small businesses; and any assumptions, data, or studies used in preparing this information. S. 4522 - Transparency in CFPB Cost-Benefit Analysis Act. The bill sets forth information required to be included in a rulemaking made by the Consumer Financial Protection Bureau (CFPB). Specifically, the CFPB must publish a justification of the proposed rulemaking; a quantitative and qualitative assessment of all anticipated direct and indirect costs and benefits; alternatives to the proposed rulemaking; impacts on small businesses; and any assumptions, data, or studies used in preparing this information. H.R. 6038 - CFPB-IG Reform Act of 2021. The bill establishes a separate Office of Inspector General for the Consumer Financial Protection Bureau (CFPB). Currently, such oversight of the CFPB is combined with the Office of Inspector General for the Board of Governors of the Federal Reserve System.

Client expense: $120,000 · Firm income: Not reported

Government targets: 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.

Client expense: $1,010,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA), White House Office

Protect the credit union tax exemption; Oppose 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.

Client expense: $1,010,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, Veterans Affairs, Dept of (VA), White House Office