Transparency in CFPB Cost-Benefit Analysis Act

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. 1270, Prohibit Auto Insurance Discrimination (PAID) Act H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 4277, Overdraft Protection Act of 2021 H.R. 5911, Fair Hiring in Banking Act H.R. 6814, Small Business Fair Debt Collection Protection Act H.R. 7412, Transparency in CFPB Cost-Benefit Analysis Act S. 2417, Credit Access and Inclusion Act of 2021 S. 2508, Veterans and Consumers Fair Credit Act S. 3056, Prohibiting IRS Financial Surveillance Act S. 3755, Arbitration Fairness for Consumers Act Draft legislation titled Ensuring Diversity in Community Banking Act Draft legislation titled Expanding Opportunity for MDIs Act Draft legislation to provide a right of removal to federal court from CFPB administrative adjudication House companion legislation to S. 2417, Credit Access and Inclusion Act of 2021 Draft legislation subjecting the Consumer Financial Protection Bureau to the appropriations process Draft legislation to replace the Consumer Financial Protection Bureau single director with a bipartisan commission Proposed rule regarding beneficial ownership information reporting requirements (86 Fed. Reg. 69,920-69,974, December 8, 2021) Proposed rule regarding Small Business Lending Data Collection Under the Equal Credit Opportunity Act (Regulation B) (86 Fed. Reg. 56,356-56,606, October 8, 2021) Statement of Principles for Climate-Related Financial Risk Management for Large Financial Institutions (87 Fed. Reg. 19,507-19,512, April 4, 2022) Request for Information and Comment on Rules, Regulations, Guidance, and Statements of Policy Regarding Bank Merger Transactions (87 Fed. Reg. 18,740-18,744, March 31, 2022) Notice and Request for Comment Regarding Fees Imposed by Providers of Consumer Financial Products or Services (87 Fed. Reg. 17,996-17,997, March 29, 2022) Proposed rule regarding Community Reinvestment Act (87 Fed. Reg. 33,884-34,066, June 3, 2022) Advance notice of proposed rulemaking; extension of comment period, regarding credit card late fees and late payments, (87 Fed. Reg. 42,662, July 18, 2022) Various issues relating to structure and independence of the Consumer Financial Protection Bureau; artificial intelligence and machine learning; DOJ Bank Merger Competitive Analysis; OCC Request for Feedback on Principles for Climate-Related Financial Risk Management for Large Banks

Issues regarding NDAA Issues related to the Consumer Financial Protection Bureau Fair Debt Collections Act Rulemaking Issues related to Arbitration Issues related to Student Lending Issues related to Debt Collection Issues related to Medical Debt Issues related to call blocking and labeling Issues related to operation Choke Point and Fair Access to Banking Issues related to the Telephone Consumer Protection Act H.R.1729 Fair Access to Banking Act S. 563 Fair Access to Banking Act H.R.7412 Transparency in CFPB Cost-Benefit Analysis Act H.R. 2547 Comprehensive Debt Collection Improvement Act Legislation related to privacy S.214 Medical Debt Relief Act S. 998 Driving for Opportunities Act

Client expense: Not reported · Firm income: $50,000

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Communications Commission (FCC), Federal Trade Commission (FTC), 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 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. 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

Issues related to the Consumer Financial Protection Bureau Fair Debt Collections Act Rulemaking Issue related to Medical Debt Issues related to Student Lending Issues related to Arbitration Issues related to Letter Vendors Issues related to COVID-19 Response Issues related to Artificial Intelligence Issues related to Credit Reporting H.R. 773- The Medical Debt Relief Act of 2021 H.R.1657- Ending Debt Collection Harassment Act of 2021 H.R.2135- Fair Debt Collection Improvement Act H.R.2458 -Non-Judicial Foreclosure Debt Collection Clarification Act H.R.2498 -Private Loan Disability Discharge Act of 2021 H.R.2537- Consumer Protection for Medical Debt Collections Act H.R.2540- Small Business Lending Fairness Act H.R.2572- Stop Debt Collection Abuse Act of 2021 H.R.2628 - Debt Collection Practices Harmonization Act H.R.2547 - The Comprehensive Debt Collection Improvement Act H.R.2453 - The Driving for Opportunity Act of 2021 H.R.4350 - National Defense Authorization Act for Fiscal Year 2022 H.R. 4773 - the Consumer Financial Protection Commission Act H.R. 133- the Consolidated Appropriations Act, 2021 H.R. 4432 - Department of Defense Appropriations Act, 2022 S. 214 - Medical Debt Relief Act S.355 - COVID-19 Medical Debt Collection Relief Act S. 823 - To amend the American Rescue Plan Act of 2021 to provide for protection of recovery rebates. S. 998 - The Driving for Opportunity Act of 2021 H.R. 7412 - The Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act

Client expense: $230,000 · 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. 4590 Promoting New and Diverse Depository Institutions Act H.R. 5376 Inflation Reduction Act of 2022 (Build Back Better) H.R. 5886 Prohibit IRS Financial Surveillance Act H.R. 5912 Close ILC Loophole Act H.R. 6037 Prohibit SBA 7(a) Direct Lending H.R. 6054 Small Business Lending Disclosure Act H.R. 6732 Small LENDER Act H.R. 6739 Business Loan Privacy Act H.R. 6802 Prevent Racial Profiling in Lending Act H.R. 6814 Small Business Fair Debt Collection Practices Act H.R. 6889 The Credit Union Board Modernization Act H.R. 7003 Expanding Financial Access for Underserved Communities Act H.R. 7412 Transparency in CFPB Cost-Benefit Analysis Act H.R. 7768 Farm Credit Administration Independence Authority Act H.R. 8152 American Data Privacy and Protection Act H.R. 8443 Making the CFPB Accountable Act H.R. 8833 The Making Communities Stronger Through the Community Reinvestment Act H.R. 8874 Credit Card Competition Act H.R. 8950 the Digital Commodities Consumer Protection Act of 2022 S. 910 SAFE Banking Act S. 1684 Federal Home Loan Banks Mission Implementation Act S. 3056 Prohibit IRS Financial Surveillance Act S. 3382 Protecting Access to Credit for Small Businesses Act S. 3715 E-Sign Modernization Act S. 3954 Ban CBDC S. 4004 Small LENDER Act S. 4356 Lummis-Gillibrand Responsible Financial Innovation Act S. 4522 Transparency in CFPB Cost-Benefit Analysis Act S. 4674 Credit Card Competition Act S. 4831 No CBDC Act Amendments 69 and 70 to FY2023 FSGG Appropriations Bill (Postal banking) Bank Merger Policy BankOn accounts Banking Services Fees Cannabis Banking Central Bank Digital Currency Climate Risk Disclosure Requirements Climate-Related Financial Regulation Community Bank Access to Capital Community Banks on Military Bases Community Development Financial Institutions (CDFI) Fund Appropriations Community Reinvestment Act Consumer Financial Protection Bureau, report of financial services in rural America Credit Reporting Credit Union Acquisitions of Community Banks Credit Union Business Lending Powers Credit Union Cybersecurity Requirements Credit Union Field of Membership Rules Credit Union Growth/Powers/Abusive Behavior Credit Union Supplemental Capital Cryptocurrency Customer Data Access, Implementation of Dodd Frank Act Section 1033 Cybersecurity Data Privacy Discussion Draft Data Security, Breaches and Privacy De Novo Bank Formation Dodd Frank Act 1071- Small Business Loan Data Collection Digital Assets Regulation Durbin Amendment on Interchange; Extension to Credit Cards FDIC Deposit Insurance Assessments FDIC Premium Increases FDIC Supervisory Appeals Review Committee and Policy Financial Data Privacy Discussion Draft Fintech Regulatory Requirements Fintech/Banking Relationships Flood Insurance Reauthorization Industrial Loan Corporation Loophole Reforms/ Rakuten (ILC) et al, Deposit Insurance Applications Interchange Interest Rate Caps Minority Depository Institutions Issues National Defense Authorization Act, Opposition to Inclusion of Credit Card Competition Act as an Amendment National Defense Authorization Act, Report Language on Financial Institution leases on military bases OCC Proposed Payments Charter Overdraft Fees Overdraft Protection P2P Payment Applications Fraud Postal Banking Protecting Consumers from Payment Scams Act (draft) SAFE Banking Act, support for inclusion in America COMPETES Act Conference SBA 7(a) Loan Program Funding and Terms SBA Direct 7(a) Direct Lending Secure Notarization Small Business Loan Data Collection--CFPB Implementation of Dodd-Frank Act Section 1071 Stablecoins Stablecoin Innovation and Protection Act of 2022 (draft) Stablecoin Legislation - Waters-McHenry Discussion Draft Stablecoin TRUST Act (draft) Unfair, deceptive, or abusive acts and practices (UDAAP)

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

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

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

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

H.R. 1270, Prohibit Auto Insurance Discrimination (PAID) Act H.R. 2547, Comprehensive Debt Collection Improvement Act H.R. 4277, Overdraft Protection Act of 2021 H.R. 5911, Fair Hiring in Banking Act H.R. 6814, Small Business Fair Debt Collection Protection Act H.R. 7412, Transparency in CFPB Cost-Benefit Analysis Act S. 2417, Credit Access and Inclusion Act of 2021 S. 2508, Veterans and Consumers Fair Credit Act S. 3056, Prohibiting IRS Financial Surveillance Act S. 3755, Arbitration Fairness for Consumers Act Draft legislation titled Ensuring Diversity in Community Banking Act Draft legislation titled Expanding Opportunity for MDIs Act Draft legislation to create a government-run credit bureau at the Consumer Financial Protection Bureau Draft legislation to provide a right of removal to federal court from administrative adjudication House companion legislation to S. 2417, Credit Access and Inclusion Act of 2021 Proposed rule regarding reinstatement of HUDs Discriminatory Effects Standard (86 Fed. Reg. 33,590-33,597, June 25, 2021) Proposed rule regarding beneficial ownership information reporting requirements (86 Fed. Reg. 69,920-69,974, December 8, 2021) Proposed interagency guidance on third-party relationships: risk management (86 Fed. Reg. 38,182-38,204, July 19, 2021) Review of Bank Secrecy Act regulations and guidance (86 Fed. Reg. 71,201-71,207, December 15, 2021) Proposed rule regarding Small Business Lending Data Collection Under the Equal Credit Opportunity Act (Regulation B) (86 Fed. Reg. 56,356-56,606, October 8, 2021) Statement of Principles for Climate-Related Financial Risk Management for Large Financial Institutions (87 Fed. Reg. 19,507-19,512, April 4, 2022) Request for Information and Comment on Rules, Regulations, Guidance, and Statements of Policy Regarding Bank Merger Transactions (87 Fed. Reg. 18,740-18,744, March 31, 2022) Notice and Request for Comment Regarding Fees Imposed by Providers of Consumer Financial Products or Services (87 Fed. Reg. 17,996-17,997, March 29, 2022) Proposed rule regarding Community Reinvestment Act (87 Fed. Reg. 33,884-34,066, June 3, 2022) Advance notice of proposed rulemaking; extension of comment period, regarding credit card late fees and late payments, (87 Fed. Reg. 42,662, July 18, 2022) Various issues relating to structure and independence of the Consumer Financial Protection Bureau; artificial intelligence and machine learning; congressional oversight of large banks; Department of Treasury proposal that would require financial institutions to report to the IRS on the deposits and withdrawals of all business and personal accounts, as well as transfers between accounts of the same owner; DOJ Bank Merger Competitive Analysis; OCC Request for Feedback on Principles for Climate-Related Financial Risk Management for Large Banks

Issues related to the Consumer Financial Protection Bureau Fair Debt Collections Act Rulemaking Issue related to Medical Debt Issues related to Student Lending Issues related to Arbitration Issues related to Letter Vendors Issues related to COVID-19 Response Issues related to Artificial Intelligence Issues related to Credit Reporting H.R. 773- The Medical Debt Relief Act of 2021 H.R.1657- Ending Debt Collection Harassment Act of 2021 H.R.2135- Fair Debt Collection Improvement Act H.R.2458 -Non-Judicial Foreclosure Debt Collection Clarification Act H.R.2498 -Private Loan Disability Discharge Act of 2021 H.R.2537- Consumer Protection for Medical Debt Collections Act H.R.2540- Small Business Lending Fairness Act H.R.2572- Stop Debt Collection Abuse Act of 2021 H.R.2628 - Debt Collection Practices Harmonization Act H.R.2547 - The Comprehensive Debt Collection Improvement Act H.R.2453 - The Driving for Opportunity Act of 2021 H.R.4350 - National Defense Authorization Act for Fiscal Year 2022 H.R. 4773 - the Consumer Financial Protection Commission Act H.R. 133- the Consolidated Appropriations Act, 2021 H.R. 4432 - Department of Defense Appropriations Act, 2022 S. 214 - Medical Debt Relief Act S.355 - COVID-19 Medical Debt Collection Relief Act S. 823 - To amend the American Rescue Plan Act of 2021 to provide for protection of recovery rebates. S. 998 - The Driving for Opportunity Act of 2021 H.R. 7412 - The Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act

Client expense: $275,000 · Firm income: Not reported

Issues related to the Consumer Financial Protection Bureau Fair Debt Collections Act Rulemaking Issue related to Medical Debt Issues related to Student Lending Issues related to Arbitration Issues related to Letter Vendors Issues related to COVID-19 Response Issues related to Artificial Intelligence Issues related to Credit Reporting H.R. 773- The Medical Debt Relief Act of 2021 H.R.1657- Ending Debt Collection Harassment Act of 2021 H.R.2135- Fair Debt Collection Improvement Act H.R.2458 -Non-Judicial Foreclosure Debt Collection Clarification Act H.R.2498 -Private Loan Disability Discharge Act of 2021 H.R.2537- Consumer Protection for Medical Debt Collections Act H.R.2540- Small Business Lending Fairness Act H.R.2572- Stop Debt Collection Abuse Act of 2021 H.R.2628 - Debt Collection Practices Harmonization Act H.R.2547 - The Comprehensive Debt Collection Improvement Act H.R.2453 - The Driving for Opportunity Act of 2021 H.R.4350 - National Defense Authorization Act for Fiscal Year 2022 H.R. 4773 - the Consumer Financial Protection Commission Act H.R. 133- the Consolidated Appropriations Act, 2021 H.R. 4432 - Department of Defense Appropriations Act, 2022 S. 214 - Medical Debt Relief Act S.355 - COVID-19 Medical Debt Collection Relief Act S. 823 - To amend the American Rescue Plan Act of 2021 to provide for protection of recovery rebates. S. 998 - The Driving for Opportunity Act of 2021 H.R. 7412 - The Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act

Client expense: $275,000 · Firm income: Not reported

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

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)

Issues regarding NDAA Issues related to the Consumer Financial Protection Bureau Fair Debt Collections Act Rulemaking Issues related to Arbitration Issues related to Student Lending Issues related to Debt Collection Issues related to Medical Debt Issues related to call blocking and labeling Issues related to operation Choke Point and Fair Access to Banking Issues related to the Telephone Consumer Protection Act H.R. 1729, Fair Access to Banking Act S. 563, Fair Access to Banking Act H.R. 7412, Transparency in CFPB Cost-Benefit Analysis Act H.R. 2547, Comprehensive Debt Collection Improvement Act Legislation related to privacy S. 214, Medical Debt Relief Act

Client expense: Not reported · Firm income: $50,000

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Communications Commission (FCC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, SENATE

Issues regarding NDAA Issues related to the Consumer Financial Protection Bureau Fair Debt Collections Act Rulemaking Issues related to Arbitration Issues related to Student Lending Issues related to Debt Collection Issues related to Medical Debt Issues related to call blocking and labeling Issues related to operation Choke Point and Fair Access to Banking Issues related to the Telephone Consumer Protection Act H.R. 1729, Fair Access to Banking Act S. 563, Fair Access to Banking Act H.R. 7412, Transparency in CFPB Cost-Benefit Analysis Act H.R. 2547, Comprehensive Debt Collection Improvement Act Legislation related to privacy S. 214, Medical Debt Relief Act

Client expense: Not reported · Firm income: $46,690

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Communications Commission (FCC), HOUSE OF REPRESENTATIVES, SENATE

Issues related to the Consumer Financial Protection Bureau Fair Debt Collections Act Rulemaking Issue related to Medical Debt Issues related to Student Lending Issues related to Arbitration Issues related to Letter Vendors Issues related to COVID-19 Response Issues related to Artificial Intelligence Issues related to Credit Reporting H.R. 773- The Medical Debt Relief Act of 2021 H.R.1657- Ending Debt Collection Harassment Act of 2021 H.R.2135- Fair Debt Collection Improvement Act H.R.2458 -Non-Judicial Foreclosure Debt Collection Clarification Act H.R.2498 -Private Loan Disability Discharge Act of 2021 H.R.2537- Consumer Protection for Medical Debt Collections Act H.R.2540- Small Business Lending Fairness Act H.R.2572- Stop Debt Collection Abuse Act of 2021 H.R.2628 - Debt Collection Practices Harmonization Act H.R.2547 - The Comprehensive Debt Collection Improvement Act H.R.2453 - The Driving for Opportunity Act of 2021 H.R.4350 - National Defense Authorization Act for Fiscal Year 2022 H.R. 4773 - the Consumer Financial Protection Commission Act H.R. 133- the Consolidated Appropriations Act, 2021 H.R. 4432 - Department of Defense Appropriations Act, 2022 S. 214 - Medical Debt Relief Act S.355 - COVID-19 Medical Debt Collection Relief Act S. 823 - To amend the American Rescue Plan Act of 2021 to provide for protection of recovery rebates. S. 998 - The Driving for Opportunity Act of 2021 H.R. 7412 - The Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act

Client expense: $180,000 · Firm income: Not reported

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

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

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. 1270, Prohibit Auto Insurance Discrimination (PAID) Act H.R. 4277, Overdraft Protection Act of 2021 H.R. 5911, Fair Hiring in Banking Act H.R. 6814, Small Business Fair Debt Collection Protection Act H.R. 7412, Transparency in CFPB Cost-Benefit Analysis Act S. 2417, Credit Access and Inclusion Act of 2021 S. 2508, Veterans and Consumers Fair Credit Act S. 3056, Prohibiting IRS Financial Surveillance Act S. 3755, Arbitration Fairness for Consumers Act Draft legislation titled Ensuring Diversity in Community Banking Act Draft legislation titled Expanding Opportunity for MDIs Act Draft legislation to create a government-run credit bureau at the Consumer Financial Protection Bureau Draft legislation to provide a right of removal to federal court from administrative adjudication Nomination of Sarah Bloom Raskin, Vice Chair for Supervision, Federal Reserve Proposed rule regarding reinstatement of HUDs discriminatory effects standard (86 Fed. Reg. 33,590-33,597, June 25, 2021) FinCEN proposed rule on Beneficial Ownership Reporting Requirements (86 Fed. Reg. 69,920-69,974, December 8, 2021) Proposed Interagency Guidance on Third-Party Relationships: Risk Management (86 Fed. Reg. 38,182-38,204, July 19, 2021); Rulemaking to implement Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (86 Fed. Reg. 56,356-56,606, October 8, 2021); Various issues relating to structure and independence of the Consumer Financial Protection Bureau; artificial intelligence and machine learning; DOJ Bank Merger Competitive Analysis; OCC Request for Feedback on Principles for Climate-Related Financial Risk Management for Large Banks; FinCEN RFI on Review of Bank Secrecy Act Regulations and Guidance; FDIC Request for Information on Climate-Related Financial Risk Management for Large Institutions; FDIC Request for Comment on Rules, Regulations, Guidance, and Statement of Policy on Bank Merger Transactions

Issues regarding NDAA Issues related to the Consumer Financial Protection Bureau Fair Debt Collections Act Rulemaking Issues related to Arbitration Issues related to Student Lending Issues related to Debt Collection Issues related to Medical Debt Issues related to call blocking and labeling Issues related to operation Choke Point and Fair Access to Banking Issues related to the Telephone Consumer Protection Act H.R. 1729, Fair Access to Banking Act S. 563, Fair Access to Banking Act H.R. 7412, Transparency in CFPB Cost-Benefit Analysis Act H.R. 2547, Comprehensive Debt Collection Improvement Act S. 214, Medical Debt Relief Act S. 3715, E-SIGN Modernization Act of 2022

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

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Communications Commission (FCC), 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. 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)

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

Protect the credit union tax exemption; Oppose Granting NCUA Oversight Authority Over Third-Party Vendors; CFPBs strategic plan; regulatory relief for credit unions; rulemaking to define abusiveness in UDAAP; provide guidance or rulemaking on special purpose credit programs (SPCP); provide guidance or rulemakings rather than rule through enforcement; provide flexibility related to New Message Format for the Fedwire Funds Service (Docket No. OP-1613); increase funding for CDFI fund, MDIs, and the CDRLF; streamline and modernize the CDFI certification process; FHFA should allow GSEs to purchase non-conforming loans from CDFIs; limit impact and burden from proposed rule related to Section 1071 Small Business Lending Data Collection (RIN: 3170-AA09); support for S.3441 - CDFI Bond Guarantee Program Improvement Act of 2022; Support legislation and regulation that helps credit unions grow membership, loans, and retained earnings in order to serve their 127 million members; Fair Market: This includes ensuring all lenders are following the same rules of the road and protecting consumers, including making fintechs, predatory payday lenders, and other non-regulated entities subject to proper oversight; Technology and Innovation: As new technologies emerge and disrupt finance, the NCUA needs to foster strong fintech partnerships to help credit unions and support credit unions ability to provide custodial services for digital assets and utilize blockchain technologies; Regulatory Relief: Remove the CFPBs examination and enforcement powers over credit unions, retain the NCUA Boards bipartisan three-member structure, and oppose efforts to place new restrictions on lending and credit reporting that will inhibit credit unions from helping their members; Data Protection: Encouraging federal standards for data privacy and data security that recognize existing regulatory requirements for credit unions, such as a federal standard of privacy rules that aligns with our principles outlined in our white paper; opposed to SBA direct lending authority; make improvements to ease the process for forgiveness of PPP loans to small businesses; support for H.R. 5189, the Member Business Loan Expansion Act; support for S. 762, the Expanding Access to Lending Options Act; oppose limits on fee income for credit unions including courtesy pay; CFPB should study overdraft programs to determine the value to consumers; limit burdens of HMDA rule on credit unions, CFPB should remove unnecessary and unused data points related to HMDA reporting; permanently increase reporting thresholds for open- and closed-end loans; response to Draft NCUA Strategic Plan 2022-2026: Ensure a safe, sound, and viable system of cooperative credit that protects consumers, Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services, and Maximize organizational performance to enable mission success; comments related to HUDs FY22-26 Strategic Goals: support for changes to the FCU Act that would allow all credit unions to serve underserved areas and create specific goals and objectives that will assist financial institutions that specialize in serving low- and moderate-income borrowers with otherwise limited access to personal, business and home financing; preclude robocall blocking rules from limiting legitimate contact of members by credit unions; extend for three years, without revision, the Recordkeeping and Disclosure Requirements Associated with Regulation II (Debit Card Interchange Fees and Routing); Support for H.R. 1996/S. 910, the SAFE Banking Act; general support for Beneficial Ownership Information Reporting Requirements (Docket No.: FINCEN-2021-26548; RIN No.: 1506-AB49) proposed rule but urges FinCEN to ensure that examination and supervisory expectations are consistent with those of other federal regulators, establish data security protocols, and maintain clarity and simplicity in its communications; prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products; comments related to Review of Bank Secrecy Act Regulations and Guidance (Docket No.: FINCEN-2021-0008) - FinCen should continue ensuring appropriate safeguards are in place to protect the financial system, should provide additional guidance related to digital assets/CVC and government fraud, should modernize and streamline the current SAR and CTR reporting thresholds, forms, and reporting mechanisms, and explore opportunities to provide feedback to credit unions regarding filed reports; comments related to Agency Information Collection Activities: Comment Request (Regulation E) (Docket No. CFPB-2021-0021) - minimized burdens associated with rule; support for S.1684/H.R. 3323 - Federal Home Loan Banks' Mission Implementation Act; support for Advancing Technologies to Support Inclusion Act; support for Creation of Diverse and Mission-Driven Community Financial Institutions Act; ease requirements for de novo credit unions; provide flexibility for credit unions to issue subordinated debt; CFPB should make greater use of Section 1022 of the Dodd-Frank Act to exempt credit unions from rules where appropriate; support for H.R. 1471, the Access to Credit for Small Businesses Impacted by the COVID-19 Crisis Act; comments related to Anti-Money Laundering Regulations for Real Estate Transactions (Docket No.: FINCEN-2021-0007; RIN No.: 1506-AB54) - limit burdens; support for Sen. Toomeys amendment to H.R. 3076, the Postal Service Reform Act; oppose expanding postal services to include financial services; oppose H.R. 963, the Forced Arbitration Injustice Repeal (FAIR) Act; support for forced arbitration - studies show consumers benefit more often from arbitration than litigation; Support for H.R. 7003 - Expanding Financial Access for Underserved Communities Act; support for S. 3745, The TAILOR Act; comments related to FHFAs : 2022-2026 Strategic Plan - FHFA should use technology to aid in appraisal modernization, create and approve pilot programs to close the homeownership gap, and work with other regulators to address climate risk; urged NCUA to initiate rulemaking to amend 12 CFR sec. 701.22 to eliminate all aggregate limits on loan participations a federally-insured credit union (FICU) may purchase from any one originating lender or to expressly exclude all loan participations purchased from a FICU from any aggregate limits on loan participations a FICU may purchase from any one originating lender; NCUA Board should prioritize regulatory reform and initiate a rulemaking to expand membership eligibility to all immediate family surviving a decedent member and redefine the term immediate family to encompass a broader range of blood and legal relatives; Treasury should address the demand for coins to help consumers who rely on cash transactions; urges IRS to issue an adjustment to the 2022 standard optional mileage rate to reflect the recent increase in gas prices; address appraisal bias and modernize the appraisal process for consistency; comments related to Request for Comment regarding Inquiry into Buy-Now-Pay-Later Providers (Docket No.: CFPB-2022-0002) - CFPB should take steps to ensure that unregulated lenders in the BNPL market institute consumer protection practices, potentially by exercising its larger participant authority over the unsecured lender market, engage in consumer education regarding the risks associated with these products and encourage BNPL providers to do the same, and in order to increase the availability of credit, while maintaining consumer protections, the Bureau should consider updates to Regulation Z that would level the playing field in the BNPL market; comments related to Pilot Program on Sharing of Suspicious Activity Reports and Related Information with Foreign Branches, Subsidiaries, and Affiliates (Docket No.: FINCEN-2022-01331; RIN No.: 1506-AB51) - FinCEN should monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements; support for H.R. 7412 the Transparency in Consumer Financial Protection Bureau (CFPB) Cost-Benefit Analysis Act; oppose any interchange/swipe fee legislation including related to routing or any form of market manipulation; parity for credit unions related to stablecoin; support for S. 4004, the Small LENDER Act; support for HR 2311, the Credit Union Governance Modernization Act.

General issues relating to flood insurance legislation. H.R. 3111, The National Flood Insurance Program Administration Reform Act of 2019; H.R. 4592, Internal Insurance Standards Act. H.R. 7011, the Pandemic Risk Insurance Act. H.R. 6494 - the Business Interruption Insurance Coverage Act H.R. 7412 - a bill to establish a temporary voluntary program for support of insurers providing business interruption insurance coverage during the COVID-19 pandemic, and for other purposes.

Client expense: Not reported · Firm income: $60,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE